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A Focus On Third-Party Practices

focus

Navex Global recently released this report titled “2017 Ethics and Compliance Third-Party Risk Management Benchmark Report.” I am always a bit skeptical of such survey data given that the results often seem to dovetail nicely with the product offering of the company publishing the survey. Indeed, a section of the report is titled “About Navex Global’s Third-Party Risk Management Solution.”

Moreover, I often wonder whether such surveys are even statistically valid. For instance, the survey was based on 427 survey respondents, with approximately 40% of respondents coming from large companies, and approximately 15% of respondents coming from the banking/financial services.

In any event, as highlighted below there are certain survey findings which caught my eye.

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Turkey

Turkey

I hope this Thanksgiving finds you enjoying and being thankful for many things in your life.

Among the many things I am thankful for are your readership and I hope FCPA Professor elevates your FCPA knowledge and skills.

May your turkey be golden brown.

The following FCPA enforcement actions have involved, in whole or in part, alleged improper conduct in Turkey.

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Downtime FCPA Reading List

Reading

Traveling for the Thanksgiving holiday and have some downtime for reading?

FCPA Professor has got you covered.

Simply need a reason to excuse yourself early from the family gathering?

FCPA Professor has got you covered as well.

This post provides an overview of FCPA writings that can help you elevate your Foreign Corrupt Practices Act knowledge, sophistication, and practical skills.

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Downtime FCPA Listening List

headphones

Traveling for the Thanksgiving holiday and have some downtime for listening?

Consider the FCPA Flash podcast.

Simply need a reason to excuse yourself early from the family gathering?

The FCPA Flash podcast can help with that as well.

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DOJ Charges Two Individuals With FCPA And Other Violations In Connection With An African Bribery Scheme On Behalf Of CEFC China Energy Company Ltd.

ChinaEnergy

Yesterday, the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

Although not specifically mentioned in the DOJ’s indictment, it is easy to connect the dots that Ho is associated with China Energy Fund Committee (CEFC) and as noted here, CEFC is “fully funded by CEFC China Energy Company Limited.” Gadio is associated with Sarata Holding (a consulting and advising firm specializing in business and development partnerships with Africa).

Big picture – in the past two weeks – the DOJ has announced three core FCPA enforcement actions involving 9 individuals. (See here for the November 7th action against 5 individuals associated with Rolls-Royce and here for the November 9th action against 2 individuals associated with SBM Offshore).

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