KPMG survey: Compliance programs aren't reaching third-party risks

From The FCPA Blog –
“KPMG International recently released the results of its global anti-bribery and corruption survey in the report, Anti-Bribery and Corruption: Rising to the challenge in the age of globalization.

The report (available here in pdf) amplifies the growing bribery and corruption risks that third parties present and the challenges companies face in monitoring these intermediaries. It also examines companies’ lack of monitoring efforts in their own anti-bribery and corruption (ABC) compliance programs. And, it explores the compliance pressures organizations face as a growing number of governments have passed ABC regulations.”

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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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Banks did not do enough to police FIFA transactions, says global agency

From Business Insider –

“A global group of government anti-money-laundering agencies said that financial institutions have not done enough to police suspicious financial activity by officials at soccer’s global governing body FIFA, and cautioned banks to step up scrutiny.

The warning from the Paris-based Financial Action Task Force came in the wake of last month’s indictment by the U.S. of nine current and former FIFA officials and five business executives on a series of corruption charges, including bribery, money laundering and wire fraud.

With the U.S. investigation continuing to widen, and a separate Swiss probe gearing up into whether there was corruption involved in FIFA’s awarding of the hosting rights to Russia and Qatar for the next soccer World Cups in 2018 and 2022, the warning will add to banks’ concern about handling certain soccer accounts for organizations and individuals.”

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