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Bribery Controls: Preparation and Training

Again, because bribery requests invariably arise in verbal and face-to-face communications, there is the opportunity to consider which employees and employee groups face these risks, and to train them appropriately. Sometimes, a factor in the bribery request is that it comes from an unexpected source or is in relation to an unexpected issue, such as the provision of utility services, which is completely counter to most employees expectations and experiences. As a consequence, they feel vulnerable, both now and for the future.

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Topics: Anti Bribery

Practical Bribery Controls

There are many practical and relatively simple bribery controls that companies can put in place, but the sad fact is that most of them don’t. Again, this is partly because of misplaced belief (see above), but also because companies believe that such controls will restrict their business, create unnecessary overhead, constrain their ability to compete, and, in any case, are too difficult to implement and sustain. Companies also often believe that since they have put in place policies, procedures, and training, their work is done.

Anticipating and Closing Down Bribery Opportunities, Including Rotating Roles

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Topics: Anti Bribery

Examples of Bribery Exposure Part 3

Misplaced Beliefs

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Topics: Anti Bribery

Examples of Bribery Exposure Part 2

Petty Cash, Expenses, Goods of Value, and Orders, Including Benford’s Law

Taken together, cash, expenses, goods, and orders represent four key sources of bribery funding from a company. A $20,000 order for a generator can, at face value, appear legitimate; however, with a simple conspiracy, that generator order can, in reality, be an order for a car intended to bribe, say, a government official; there are multiple methods through which a generator order can be turned into a car supply.

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Topics: Anti Bribery

Examples of Bribery Exposure Part 1

Companies often unwittingly expose themselves to bribery and then do not have the controls, processes, or presence of mind to recognize the risks. This is often due to a mistaken belief that “it wouldn’t happen here.”

While far from exhaustive, the list below provides some examples of how companies expose themselves to bribery.

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Topics: Anti Bribery

The Realities of Bribery—A Personal Introduction from Keith Read

Keith Read is an award-winning thought leader and expert in compliance, ethics, culture and governance. He was formerly the Group Director of Compliance and Ethics for BT (British Telecom) in London and is a past winner of the Compliance Register's Best Compliance Officer award, when he also won the Best Compliance Company award.

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Topics: Anti Bribery

The Realities of Bribery

News headlines are littered with examples of bribery allegations, often involving major, high-profile companies with good reputations and what was thought to be strong corporate governance.

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Topics: Anti Bribery

Trade Compliance 2014: OFAC Embargo and Sanctions Programs

The Office of Foreign Assets Control (OFAC) at the Treasury Department administers a variety of economic and trade sanctions programs intended to impose restrictions on trade by U.S. citizens with countries, organizations, or individuals that the U.S. government has determined pose foreign policy or national security concerns. While many of those programs see frequent changes, the U.S. embargo against Iran continues to be the most dynamic, and presents perhaps the greatest risk to U.S. exporters.

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Topics: ECA Risk Forecast Report 2014

Trade Compliance: Transfer of Lower-Level Defense Articles to Commerce Department Jurisdiction

After several years of preparatory work, the ECRI made concrete changes in late 2013 to the U.S. export control system. On October 15, export control responsibility for numerous lower-level defense articles was transferred from the State Department to the Commerce Department. Historically, the Commerce Department was responsible only for regulating the export of dual-use articles (items with both commercial and military utility), while the State Department was responsible for regulating the export of defense articles. With the recent transfer of certain less sensitive defense articles to the Commerce Control List, the Commerce Department now has jurisdiction over both dual-use articles and certain lower-level defense articles.

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Social Media in the Workplace

Social media increasingly play a role in just about all stages of the employment process—and at each stage there are compliance risks.

Many companies, for example, regularly look up job applicants online as part of the hiring process. But according to a 2013 study by researchers at Carnegie Mellon University, many may also use what they find to discriminate. In an online experiment, the researchers tested responses of over 4,000 U.S. employers to a Muslim candidate relative to a Christian candidate, and to a gay candidate relative to a straight candidate. They found that “survey subjects with hiring experience are significantly less likely to say they would interview the Muslim candidate than the Christian candidate.” (However, researchers found no evidence of discrimination against the gay candidate relative to the straight candidate.)

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Topics: ECA Risk Forecast Report 2014

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Tackling compliance and ethics issues from around the world.

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