tagged w/ eLandia
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A recent benchmarking survey of Third Party Codes of Conduct was conducted by the Society of Corporate Compliance and Ethics (SCCE) and reported on by Rebecca Walker. The findings indicated that a majority of companies with an otherwise robust compliance program do not extend this to third parties with which they conduct business. For those companies who now desire to evaluate their third party business partners for Foreign Corrupt Practices Act (FCPA) compliance, how and where do they begin?
http://information-security-resources.com/2010/03/04/risk-based-enterprise-compliance-programs/A recent benchmarking survey of Third Party Codes of Conduct was conducted by the... more
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The landscape of the Foreign Corrupt Practices Act (FCPA) is littered with cases involving both agents and resellers are they are the most clearly acting as representatives of the companies whose goods or services they sell for in foreign countries. However many US businesses believe that the legal differences between agents/resellers and distributors insulate them from FCPA liability should the conduct of the distributor violate the Act. If you have a distributor, it must be subjected to the same FCPA scrutiny and management as an agent, reseller or joint venture partner…
http://information-security-resources.com/2010/02/18/resellers-and-distributors-under-the-fcpa/The landscape of the Foreign Corrupt Practices Act (FCPA) is littered with cases... more
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These changes to the Sentencing Guidelines should be monitored closely by companies as they represent significant amendments to the Sentencing Guidelines. It appears that the Department of Justice is moving to force companies to place compliance and ethics in a higher profile within their organizations and not simply to pay lip service, along the lines of “we have a code of ethics and act responsibly”…
http://information-security-resources.com/2010/02/11/changes-in-law-for-fcpa-ethics-compliance/These changes to the Sentencing Guidelines should be monitored closely by companies as... more
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The recession has lessened and all that cash your Company has been hoarding for the rainy days of the Obama years is burning a whole in your CEO’s pocket. He has his powder dry and is ready to make a big bang by going on a buying spree, targeting overseas entities, to beat the competition in coming out of your industry’s downturn. An initial inquiry should be made into the ownership structure of the target company. If any portion of the entity is owned or held by a government or governmental entity then such an entity is covered under the FCPA as a foreign governmental instrumentality…
http://information-security-resources.com/2010/02/03/the-fcpa-role-in-international-acquisitions/The recession has lessened and all that cash your Company has been hoarding for the... more
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