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A Focus On Third-Party Practices


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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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

Make your voice heard regarding Canada’s quest for deferred prosecution agreements. This post highlights my submission to the Government of Canada by highlighting that Canada’s justifications for DPAs are based on assumptions about DPAs in the U.S. that lack evidence or assumptions undermined by actual evidence.

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Reading Assignment For All Executive Officers: The Mace Enforcement Action

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The recent Foreign Corrupt Practices Act enforcement action against Anthony Mace (the former CEO of SBM Offshore) is a must read

FCPA lawyers should send this post to their clients. In-house counsel and other compliance professionals should send this post to their executive officers and the Mace enforcement action should make its way into FCPA training and communications.

For starters, criminal FCPA enforcement actions against large company employees are unusual. (As highlighted in this prior post, the vast majority of individual criminal FCPA enforcement actions are against persons associated with small, privately held business organizations).

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Go “Back To School” At The FCPA Institute – Phoenix (Jan. 11-12th)

Featured Image FCPA Institute

Learning a new topic or elevating your knowledge and practical skills in a topic is not just for formal students in formal educational settings. Professionals in the workplace can also benefit from a “back to school” experience.

For professionals in the FCPA space – or wishing to join the FCPA space – the FCPA Institute serves this objective and the next FCPA Institute will take place in Phoenix on January 11-12, 2018.

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Could Someone In Your Organization Benefit From A Two-Day, Active FCPA Learning Experience?

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Could someone in your organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute in Phoenix on January 11-12, 2018.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of a diverse group of professionals through active learning and I would be grateful if you could help spread word of the upcoming FCPA Institute – Phoenix among your contacts and colleagues.

The below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

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