Corruption, Forced Labor and Human Trafficking in Supply Chains Subject Unsuspecting Companies to Potential FCPA Violations

Increasingly,  trafficking-related activities in global supply chains include corruption, bribery, and other conduct that could result in liability for companies subject to Foreign Corrupt Practices Act (FCPA) jurisdiction. Both sending countries and countries employing forced labor can be liabilities for companies unknowingly using unscrupulous agents. Companies can avoid FCPA prosecution by instituting an effective, functioning compliance program. Routine FCPA Due Diligence is a critical component in maintaining a FCPA compliance program.

If you or your company is subject to, or suspects potential supply chain issues, contact our experienced attorneys. Attuned to detail, Kennyhertz Perry’s investigations are unparalleled in quality, exceeding the highest standards.

Real Estate Compliance and CFPB Compliance

Recently, Braden Perry discussed Real Estate encryption and client privacy with Virtru Business Solutions Blog and described how the Consumer Financial Protection Bureau (“CFPB”) monitors compliance and privacy.

The CFPB is designed to help consumers across the financial industry, said Perry. And company culture is often the biggest obstacle to CFPB compliance: “Many regulated companies are “reactive,” meaning that they do not anticipate issues but wait for issues to arise and then act or “react.” [They’re] short-sighted, looking at the near-term and not focused on long-term goals. “Proactive” companies are forward looking, not only in anticipating issues that might arise, but in having clear directions and goals.”

Perry recommended that companies remain open to change. Reactive organizations tend to resist security initiatives, creating an “uphill battle” for compliance staff. To succeed, organizations need full management buy-in.