On the Death of Cecil the Lion and the FCPA

From Compliance Week –

“Cecil the Lion was shot and killed in July. What does the death of this well-known and well-beloved lion in Zimbabwe have to do with the Foreign Corrupt Practices Act? More importantly, what are the lessons to be learned by any chief compliance officer or compliance professional from this event? Much more than you would first think, actually.

A U.S. citizen, Dr. Walter Palmer, a dentist who is a big game hunter aficionado, killed Cecil. As a U.S. citizen, he is subject to the FCPA anywhere outside the United States. Palmer employed third parties to assist him in obtaining a benefit, which in Palmer’s case was his hunt that ended in the death of Cecil the Lion. These third parties obtained various governmental permits from the Zimbabwean government to allow him to hunt in that country. These same third parties acted as hunting guides to Palmer and are alleged to have lured Cecil the Lion illegally off a protected game reserve through criminal conduct in violation of Zimbabwean law.

All of this conduct could be violations of the FCPA, and Palmer could face five years in jail for each FCPA violation.”

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Anti-Corruption Compliance

Understanding the OECD Anti-Bribery Convention, the US' Foreign Corrupt Practices Act (FCPA), and the UK Anti-Bribery Act.

Dubai, 26/27 August 2015

This 2-day training course is a practical look at corruption and current anti-corruption practices at a level that will provide both a clear definition and broad guidelines as to how this scourge can be fought. The in person seminar will discuss and detail issues and checklists to help make setting up your own anti-corruption program easier.

The seminar instructor will use a combination of prepared tuition, examples, discussions, exercises and case studies. For instance, the prominent Siemens case study that will be discussed will examine the corruption scandal and the steps that Siemens subsequently took to recover from this disaster.

This interactive course will offer participants the opportunity to share experiences and plan work within small working groups, providing practice in the application of the techniques and tools, and generating active participation.

Click here for the workshop agenda and learning objectives and to REGISTER.

Developments From Across the Pond

From FCPA Professor –

“The SFO Loses Another Bribery Trial

It is one thing for a law enforcement agency to allege a crime.

It is quite another for a law enforcement agency to prove a crime to someone other than itself.

In legal systems based on the rule of law, the later matters more than the former; however it seems that more attention is paid to the former rather than the later.’

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The FIFA Corruption Scandal: What Companies Should Take Away

From Risk Management & Crisis Response –

“What can companies take away from the United States Department of Justice’s arrest of several senior FIFA officials last week, and ongoing investigation into corruption in soccer? Indictments were issued against 14 individuals and seven were arrested last Wednesday on charges of racketeering, wire fraud and money laundering conspiracies, among other charges; the DOJ has also indicated more indictments are likely.”

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