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The Trend of Overlapping Enforcement of Anti-Corruption and Export Controls
[Editor's Note: This article was contributed by previous CCI featured author Wendy Wysong, a partner at Clifford Chance, along with her co-authors Adam Klauder and Megan Gordon, both associates at...
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Export Control Violations: Best Practices for Conducting Effective Global...
(This article was originally published on August 24th, 2009 and was contributed to Corporate Compliance Insights by Wendy Wysong, a partner at Clifford Chance US LLP in the White Collar &...
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Anti-Kickback and Stark Investigations: Attention Intensifies
[Editor's note: This article was originally posted on December 7th, 2009.] ———- Introduction: Health care providers, whether physicians or hospitals, should be critically reviewing their longstanding...
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State-Owned Enterprises: An FCPA Risk You Can’t Ignore in Asia
Companies operating in the Asia Pacific region, where state-owned or controlled entities are commonplace, have been warned again of the particular risks they face. In a series of recent rulings, the...
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Third-Party Intermediaries in China: Mitigating A Necessary Risk (Part 1)
Virtually every article written on successfully doing business in China mentions the importance of using an intermediary (a zhongjian ren) to make introductions, provide language and cultural...
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Third-Party Intermediaries in China: Mitigating A Necessary Risk (Part 2)
On Monday Wendy discussed why companies should take careful measure of the FCPA compliance risks of using third-party agents in China. Today she provides policy recommendations when dealing with third...
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U.S. Anti-Boycott Laws Reach To China
A recent anti-boycott investigation of the Shanghai branch of a major U.S. bank (the Bank) serves as an alert to branches and subsidiaries of U.S. companies located in China. Foreign branches of U.S....
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Indexing Corruption in Asia Pacific
This month, Transparency International (TI) released its 2011 Bribe Payer’s Index (BPI). Companies seeking to accurately assess the risk of doing business in Asia Pacific or with a partner from the...
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The Asia Pacific Top 10 FCPA Cases of 2011
Continuing to focus an unblinking eye on the Asia Pacific region, U.S. anti-corruption enforcement authorities resolved 10 investigations in 2011 against companies operating in that region under the...
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Under-Criminalisation of Foreign Bribery in Asia Pacific
Countries signing on to the United Nation Convention Against Corruption (UNCAC) are required to enact laws to criminalize bribery of foreign public officials. All of the Asia Pacific countries (except...
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Private Sector Bribery In Asia Pacific: Where Are We?
Until recently, public officials have been the main focus of anti-corruption efforts, both in Asia Pacific and the world. Concern about the probity of government officials as well as media attention...
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A Dozen Chances to Do It Right: Decision Points for Export Compliance
When investigators are forming their view as to whether a non-U.S. company should be criminally prosecuted for violations of U.S. export controls and economic sanctions, they examine the company’s...
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Tone Deaf at the Top: Encouraging Top-Down Compliance in Asia Pacific Companies
Not infrequently, our introduction of the concept of “Tone from the Top” commitment to compliance has been met with open-mouthed astonishment and, in some cases, suspicion or even rejection by Asia...
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AML Compliance Challenges for Casinos in Asia Pacific
Keeping the cards close to the vest is not the best strategy for casinos trying to avoid being used as money laundering outlets. Rather, transparency trumps secrecy. This is particularly true for...
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U.S. FCPA Jurisdiction in Asia Pacific: To Infinity and Beyond?
Recent cases brought by U.S. law enforcement have made it clear that companies who are not incorporated or operating in the United States, not listed on U.S. stock exchanges, and not doing business...
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Chocolate to Chai: Developing a Culturally Appropriate Keyword Search List
In conducting internal investigations of suspected corrupt conduct occurring outside the United States, one of the challenges is developing a keyword search that will surface bribery in all of its...
View ArticleTen Hallmarks of Effective Compliance Programs for Asia Pacific Companies
Designing a corporate compliance program for companies operating in Asia Pacific sometimes feels like trying to fit a round hole around a square peg. No amount of pounding will smooth the edges off a...
View ArticleAsia Pacific Anti-Corruption Rankings for 2012
Transparency International’s recently released Corruption Perceptions Index 2012 reveals important new data for companies operating in Asia Pacific. There is some improvement and some backsliding...
View ArticleThe Asia Pacific Top 10 FCPA Enforcement Actions of 2012 (Part One)
The following is the first in a two-part series by Wendy Wysong The Asia Pacific region remained a hotspot for US anti-corruption enforcement authorities in 2012. Six of the twelve corporate Foreign...
View ArticleThe Asia Pacific Top 10 FCPA Enforcement Actions of 2012 (Part Two)
The following is the second in a two-part series by Wendy Wysong Part One of this article discussed the six corporate Foreign Corrupt Practices Act (FCPA) settlement agreements in 2012 that involved...
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