Can your compliance program withstand the new aggressive focus on corporate crime by the US Department of Justice (DOJ)?
Read more
France: Green Light for a new Sapin 3 Anticorruption Law
The Compliance Lady AFA, CJIP, CORPORATE CORRUPTION, Corruption, EU, France, SAPIN II, SAPIN III, Whistleblower
Five years after Sapin 2 law was born, Bruno Le Maire’s cabinet gives the green light for what sounds like a new “Sapin 3” law. The Sapin 2 law marked a real turning point in the fight against corruption in France by introducing significant changes into law, creating the French Anticorruption Agency (AFA), and adding…
Read more
Pandora Box, and American Kleptocracy
Some reflections on the Pandora Papers revelations, and a new must-read book to make sense of it all.
Read more
US Investigating Raytheon for bribery of Qatar Royal Family Member
Qatar Bribery: Last year, while reporting that U.S. authorities were investigating Raytheon Technologies Corp. for improper payments in the Middle East, I posited a hypothesis that the investigations were related to a California Court case stemming from a soured consultancy agreement with the State of Qatar (Tarek Fouad v. the State of Qatar). My hypothesis…
Read more