Category Archives: law

Achieving better results from public sector institutions

Submitted by Linda Van Gelder [View] After a year of intensive consultation among development partners and with technical experts within the World Bank, I am pleased to announce that the World Bank Approach to Public Sector Management (2011-2020) has been agreed by the Public Sector Governance Board (the internal body that maintains professional standards on PSM and governance

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Conduit to Compliance or First Line of Defense – the Local Compliance Point Person

As compliance programs mature, it is becoming increasing clear that one size does not fit all. Moreover, there may be several different approaches to creating the most effective compliance program for your organization. This past week I attended the ACI FCPA Boot Camp in Houston. Many of the presentations dealt programs, procedures and process companies

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The Power of Documentation : Transparency Inconsistent with Criminal Intent

Documentation of decision-making provides critical protection from individual or corporate criminal liability.  In the absence of a contemporaneous record of why an individual/ company made a decision, such an entity may be exposed to allegations of improper actions and intent and particularly if the allegations are untrue, would have lost a critical opportunity to provide

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The Anatomy of Corruption in Public Procurement

Public procurement presents significant risk under the U.S. Foreign Corrupt Practices Act (FCPA). Cases like Siemens Argentina, Siemens Venezuela, Johnson & Johnson, and Tenaris highlight the risk. Large amounts of money are at stake when the government procures things like roads, computer systems, oil extraction services, medical equipment, power stations, and textbooks. Companies must interact directly

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Another BRIC in the Anti-Corruption Wall (Brazil considers foreign bribery law overhaul)

The Brazilian Congress is now considering Draft Bill 6.826/2010 that would dramatically strengthen its foreign bribery law. This is a significant development – the result of years of effort by Brazilian authorities working closely with their OECD, United States, and other counterparts. It is also timely. Sophisticated Brazilian-based multinationals are quickly expanding internationally, and encountering corruption

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