UK Bribery Act of 2010

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The FCPA and Fight Against Terrorism

I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in DOJ and SEC enforcement of the Foreign Corrupt Practices Act (FCPA).

Challenges to Combating Bribery and Corruption

It’s seems obvious to say that corporate leaders would prefer to steer clear of bribery and corruption violations, especially given all of the recent media attention surrounding enforcement of the FCPA and UK Bribery Act.

U.K. Ministry Of Justice dpa

The U.K. Ministry Of Justice Should Say No To DPAs In Context Of The Bribery Act

This article originally appeared on Professor Koehler’s FCPA Professor website ( and is reprinted with his permission. As noted in this prior article, the U.K. Ministry of Justice (“MoJ”) has a consultation process open concerning its proposal to adopt deferred prosecution agreements.  Below is the text of my letter to the MoJ urging it to say no to DPAs in the Bribery Act context.  You too can […]

Anti-Corruption Programs

Anti-Corruption Programs: Think Strategically

In the face of ever more aggressive enforcement of anti-corruption and wider anti-financial crime legislation, the management teams of even the most well-prepared multinational companies are asking themselves not “if,” but “when” they will have to take their organization through a regulatory investigation.

oecd phase 3 report

The U.K. OECD Phase 3 Report

The OECD recently released its Phase 3 Report on Implementing the OECD Anti-Bribery Convention in the United Kingdom. Mike Koehler provides a brief overview of certain issues in the report.

compliance risk jpmorgan chase

JPMorgan Chase’s Lesson on Compliance Risk

Most of the business news last week has been dominated by JPMorgan Chase & Co.’s (JPM) announced $2.3 billion trading loss. Early on there was focus on JPM’s trading operations in London, as the cause of this massive loss and even one trader, nicknamed the “London Whale,” has fueled the debate about banks taking such large positions, […]