International Law

Release 07-02, Where Are You?

Posted on December 05, 2007
We noticed a week ago that U.S. Department of Justice Opinion Procedure Release No.: 07-02 (September 11, 2007) is missing. It no longer appears on the DOJ's website that indexes all FCPA Releases (here). The text of the Release is still available from the old link here, but not through the index...

An Effective Compliance Program Redux

Posted on December 04, 2007
The question that lands most often in our mailbox is this: What are the elements of an effective Foreign Corrupt Practices Act compliance program? It's a great question. While proactive compliance programs reduce the chances of violations, no one can guarantee that a violation will never happen...

The Empty Chair

Posted on December 02, 2007
It's official. Britain's absence from the global war on public corruption is now a full-fledged scandal. Nearly ten years after the U.K. ratified the Anti-Bribery Convention of the Organisation for Economic Co-operation and Development (OECD), there hasn't been a single British prosecution...

One Of Congress's Finer Moments

Posted on November 29, 2007
The Wall Street Journal has an editorial in its November 28, 2007 edition about the U.S. Foreign Corrupt Practices Act and the world-wide battle against public corruption. "Global Cleansing" is available here (but the online WSJ is still by subscription only)...

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"Payload" Is An FCPA Watershed

Posted on November 28, 2007
Visitors to this blog -- if they haven't done so already -- will want to read an outstanding article from the November 25, 2007 edition of the New York Times. It's called "Payload: Taking Aim at Corporate Bribery." The lengthy piece about the U.S. Foreign Corrupt Practices Act is by Nelson D...

Will The Local Law Defense Help BAE?

Posted on November 26, 2007
BAE Systems is being investigated by the U.S. Department of Justice for possible violations of the Foreign Corrupt Practices Act. It allegedly paid £1 billion to Saudi Prince Bandar in return for his helping BAE sell 72 Typhoon jet fighters to Saudi Arabia...

The U.S. Is Gathering Evidence Against BAE

Posted on November 25, 2007
The U.K. and Saudi governments deny that any laws -- including the U.S. Foreign Corrupt Practices Act -- were broken. But questions persist about the £1 billion payment earlier this year by U.K. defense giant BAE Systems to Prince Bandar, the former Saudi ambassador to the U...

Will Nigeria Hit The Boiling Point?

Posted on November 19, 2007
The online edition of Nigeria's Business Day newspaper carried a story on November 19, 2007 that's noteworthy. It's about how corrupt multinationals are undermining the country's economy. The story can be found here. Public corruption always involves two parties -- the crooked official and the bribe-paying privateer...

All Eyes Are On Siemens

Posted on November 18, 2007
The Big Show these days for followers of the U.S. Foreign Corrupt Practices Act is Siemens' global bribery scandal. To wit, the print and online versions of the November 16, 2007 Wall Street Journal carried a brilliantly reported Page One story based on the fact statement compiled by the Munich public prosecutor ("Ruling Details Bribery Across the Globe")...

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