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How to Craft an Anti-Corruption Policy Without a Legal Department
A small company does not need a large legal function to create a credible anti-corruption policy. It needs clear standards, practical procedures, accountable…
The US Travel Act And Cross-Border Commercial Bribery
Cross-border commercial bribery can expose a company to several overlapping legal regimes. A payment to a private-sector decision-maker may fall outside the…
Managing corruption risks across maritime trade and port operations
Maritime commerce depends on a chain of public and private decisions made under time pressure. Customs officers release cargo, port authorities allocate…
Best Practices for Documenting Due Diligence for Regulatory Inspections
Regulatory inspections rarely focus on whether a company has a policy sitting in a shared drive. Inspectors want to see how the organization identified risk,…
Managing the Risks of Facilitating Third-Party Introductions to Government Officials
Businesses often rely on advisers, consultants, distributors, law firms, and local partners to reach public institutions. An introduction can help a company…
Building an Effective Corrective Action Plan After an Audit
A compliance audit finding is more than a record of something that went wrong. It is evidence that a policy, control, process, or decision-making practice did…
Managing Compliance Where the Rule of Law Is Weak
Operating in a country with weak rule of law can expose a company to risks that are difficult to identify through legislation alone. Laws may exist on paper…
How Forensic Accounting Exposes Hidden Bribery Payments
Bribery rarely appears in a company’s records as a clear payment labeled “illegal commission.” It is more often disguised as a consulting fee, marketing…
Responding to an Overseas Official’s Bribe Request
An overt request for a bribe from a government official can place an employee and a company under immediate pressure. The demand may be presented as a “fee,”…
Understanding Active And Passive Bribery In Civil Law Countries
Bribery laws often describe the same corrupt exchange from two different sides. Active bribery generally concerns the person who offers, promises, or gives an…
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