ISO 37001 Archives - FCPA Professor

The Latest Laughable ISO 37001 Marketing Effort

By Mike Koehler on April 11, 2019 in ISO 37001

Since its release in October 2016 (see here) much has been written about ISO 37001 and one’s view of it likely depends on one’s background, experience and motivation.

If you are familiar with the numerous sources of best practices in the anti-bribery space, then ISO 37001 was (and remains) a complete yawner, indeed a disappointment as several best practices are not even captured in ISO 37001.

If you are not familiar with the numerous sources of best practices in the anti-bribery space, and/or you are seeking to market your compliance practice then ISO 37001 was (and remains) probably a big deal.

Friday Roundup

By Mike Koehler on February 15, 2019 in Antonio Maarraoui, Caliburn International, Cobalt International Energy, Collateral Effects, ISO 37001, Miguel Loya, Sallyport, Vitol

Never mind that …, “foreign official” charges, scrutiny alert, ISO-37001 related, and ethics inquiry up north. It’s all here in the Friday roundup.

Never Mind That …

Never mind that Cobalt International – not once, but twice – beat back the government in connection with FCPA scrutiny in Angola (see prior posts here and here as well as this podcast).

Nevertheless, a federal court judge recently approved an approximate $175 million settlement of investor class action claims alleging various securities laws violations by Cobalt related to its FCPA scrutiny (see here). As to the plaintiffs’ lawyers, well they get 25% of that amount plus approximately $2 million in reimbursement of litigation expenses.

Friday Roundup

By Mike Koehler on June 22, 2018 in Africa Sting, Bilfinger, Compliance, Enforcement Agency Speeches, ISO 37001, Root Causes

ISO 37001 airball, from the Inspector General report, scrutiny alert, good lord, marketing an impossible dream, root causes, and yes it is. It’s all here in the Friday roundup.

ISO 37001 Airball

If you have an interest in the non-story of ISO 37001 check out this podcast in which Alexandra Wrage (Trace International) asks some very good questions of a Microsoft representative.

To use a basketball analogy, the Microsoft’s reps answers were air balls full of buzzwords and cliches.

Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

By Mike Koehler on June 4, 2018 in 2018 Enforcement Actions, Anything of Value, DOJ Enforcement Action, Financial Services Industry, ISO 37001, Legg Mason, Libya, Third Parties, Travel and Entertainment, Undercover Investigations

A few hours after the DOJ announced a net $293 million Foreign Corrupt Practices Act enforcement action against Société Générale S.A concerning conduct in Libya that occurred 9-14 years ago (see here for the prior post), the DOJ also announced that investment management firm Legg Mason also agreed to pony up $64 million to resolve a related enforcement action.

Pursuant to a three-year NPA, Legg Mason agreed to pay $64 million based on the conduct of “only two mid-to-lower level employees of a subsidiary of the company” (specifically Permal Group Ltd.). According to the DOJ: “Permal’s financial statements were consolidated into Legg Mason’s financial statements and they participated in a net revenue sharing arrangement, and all employees of Permal were subject to Legg Mason’s code of conduct.”

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Legg Mason Also Ponies Up $64 Million To Resolve FCPA Enforcement Action Concerning Conduct In Libya That Occurred 9-14 Years Ago By “Only Two Mid-To-Lower Level Employees Of A Subsidiary”

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