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The Blue Geranium – SEC Enforcement of the FCPA – Part III
In Christie’s The Blue Geranium a difficult and cantankerous semi-invalid wife is looked after by a succession of nurses. They changed regularly, unable to cope with their patient, with one exception...
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The Intersection of the FCPA, TI-CPI and Tax Appeals in Brazil
The Transparency International-Corruptions Perceptions Index (TI-CPI) is released each year in November. The TI-CPI rates Brazil as 69th out of 175 countries on its index, coming in with a score of 43...
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On the Oregon Trail: the BHP Enforcement Action and High-Risk Hospitality
Today we celebrate American exceptionalism. As noted in ‘This Date in History’, on this date in 1834 the first wagon train, made up of 1,000 settlers and 1,000 head of cattle, set off down the Oregon...
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Economic Downturn Week, Part I – Mapping of Your Internal Compliance Controls
This week I will present a series on steps that you can take in your compliance program if you find yourself, your company or your industry in an economic downturn. All of the recommendations I will...
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The War of 1812 and the IAP Worldwide Services Non-Prosecution Agreement
On this day, 203 years ago, President James Madison signed a Declaration of War against Great Britain inaugurating the War of 1812. The cause of the war was multi-faceted; the formal reason given was...
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Tribute to John David Crow and an Innovation Strategy for Your Compliance...
John David Crow died Wednesday. Until Johnny Football, he was the only football player from Texas A&M University to win the Heisman Trophy. He played under the legendary Paul ‘Bear’ Bryant at...
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What Would Dr. Seuss Say about an Allowance?
Earlier this month we had the release of a second book by Harper Lee, “Go Set a Watchman”, which was miraculously discovered having been written some 50+ years ago. This week, there was another release...
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The BHP Case and Enforcement of The FCPA’s Internal Controls Provision
Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action....
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BNY Mellon Settles First Sons and Daughters (and Nephews) FCPA Hiring Matter...
Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was...
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BNY Mellon and Lessons Learned In Hiring Family Members – Part II
In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around...
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