Code of conduct is a reference book for every ethics & compliance professional and every compliance officer probably knows company’s code of conduct by heart. But, have you ever asked yourself why code of conduct is so important for businesses all around the globe? Does it bring any tangible value to a company? Lastly, what happens if a company chooses not to have one?Read More
The US proposes a new law which, if adopted, will require everyone crossing US border to declare their bitcoins worth over $10k. The offenders will face criminal charges. Why do I think this initiative has pretty good chances to see the light of the day?Read More
On 18 February 2016, US DoJ and SEC announced “a global settlement that requires telecommunications provider VimpelCom Ltd. to pay more than $795 million: $167.5 million to the SEC, $230.1 million to the U.S. Department of Justice, and $397.5 million to Dutch regulators.” ...Read More
According to DoJ Announcement of December 20, 2013,“Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM (Archer Daniels Midland Company), pleaded guilty and agreed to pay more than $17 million in criminal fines to resolve charges that it, in violation of FCPA ...Read More
In the first part of this post I rather touched the theoretical part, i.e. what the law exactly says; now is the time to see real life examples of how FCPA is enforced and its extended overseas reach.
It is important to note that interpretation of legislation has always been a privilege of the judicial ...
Every now and then we see the headlines about some company or organization is being pursued for committing acts of corruption in different parts of the world. One could think about the latest FIFA corruption scandal or the Forbes listed Mr. Dmytro Firtash, who was detained in Switzerland ...Read More
On September, 9, 2015, the U.S. Department of Justice had issued a new memorandum authored by Deputy Attorney General Sally Quillian Yates entitled “Individual Accountability for Corporate Wrongdoing”. The memo refocuses government enforcement inquiries on individuals and sees ...Read More
Contributions and donations to charitable and non-charitable non-profit organizations (i.e., payments to support certain activities of organizations, donation of working space, corporate sponsorships, product donations, monetary donations, etc.) are an accepted and customary practice, both in ...Read More
Providing gifts when doing business is an appropriate way to show respect or gratitude and to build stronger business relationships. Public perception of gifts differs depending on a particular country or region, however, under certain conditions gifts might cause concerns notwithstanding distinctions in ...Read More
Speaking with specialists in compliance field and managers of Ukrainian branches I realized that many of us do not read essential readings and rely only on internal company’s policies, procedures, frameworks, trainings and guidance. Indeed it is wise and important to build global consistency in ...Read More