Due Diligence – Howard@OpenAir

Howard@OpenAir

Due Diligence

FINCEN & Customer Due Diligence

I'm looking for someone to talk to who was at the public hearing on the new FINCEN regulation. The one that requires collection of beneficial owner information.

Three Truths About Due Diligence

We hear a lot about due diligence and its importance to effective anti-corruption controls. It amazes me that people who universally recognize the need to do it well still do it so badly. I read Mike Volkov’s article on his blog yesterday about due diligence programs. First, a quick digression: make sure you go over to Mike’s blog […]

What to Do About the UK Bribery Act

This past week, I was on a webinar with Mark Mendelsohn (the replay can be found here: http://bit.ly/gTAeKB). One of the things we spoke about was what companies need to do now to comply. I was a little more sanguine than Mark was; I thought that we should wait and see whether the UK actually […]

Case Study #6: How Much Diligence is Due?

I had been waiting for the hospitality case study. Everyone else has been waiting for this one: due diligence of agents. Diligence presents a number of difficulties for companies of all sizes. It’s like the old journalism class I took: the question words. Who? What? Where? When? Why? In fact, that’s a good mental framework for […]

After the Bribe

The first thing I do in the morning, via my Google Reader, is read a few FCPA-related blogs. One of these is the FCPA Professor. An excellent source of information. Today, he brings word of a quiet settlement by the Ball Corporation. Reading it, Prof. Koehler quotes from the SEC’s cease-and-desist proceeding (the least stringent […]

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