GCSG issues Malaysia compliance risk profile

Global Compliance Solutions Group LLC (GCSG) issues Malaysia country compliance risk profile

GCSG distributes Malaysia, our fourth country compliance risk profile – our risk profiles provide business, compliance, and risk professionals with a snapshot of relevant governance, trade compliance, and anti-bribery and corruption risks

PRAIRIEVILLE, LA – GCSG, a professional compliance management consulting company, today issues Malaysia our fourth country compliance risk profile (“risk profiles”).  The risk profiles are intended for business, compliance and risk professionals concerned with governance, trade compliance, and anti-bribery and corruption compliance risks in countries in which they do business. 

Each risk profile is designed to provide a snapshot of a targeted set of compliance risks within each country to assist the user with understanding the risks in that country as they look to diversify their supply chains, acquire a new business, or improve their knowledge of a country they currently operate within. 

We are excited to build on our client focused services with the launch of our free country compliance risk profiles because we believe they will bring value to the user,” said Jonathan Mellard, Founder, GCSG. 

Each risk profile provides a concise view of relevant legislation, risks, and the current environment.  Every risk profile incorporates a risk ranking for each category and for the country overall.  The risk ranking is determined using our Compliance Risk Index (CRI), a tool that analyzes a combination of publicly available factors and then calculates and assigns a score for potential risk at the country level.   

Our first three profiles were Vietnam, Myanmar, and Indonesia. Interested parties should periodically check our country risk profiles web page as we continue, over time, to add more profiles.

This Malaysia risk profile was written in collaboration with the Malaysian office of Rahmat Lim & Partners.

Access the Malaysia risk profile: http://www.globalcompliancesg.com/s/Malaysia-Country-Risk-Profile-ee42.pdf

Access our country risk profiles web page: http://www.globalcompliancesg.com/country-risk-profiles

** *** **

Global Compliance Solutions Group LLC

Global Compliance Solutions Group LLC (GCSG) is headquartered in Louisiana, USA.  We provide international Advisory, Audit, and Due Diligence products and services wherever our clients are located across a range of industries in the areas of Anti-Bribery and Corruption, Import, Export, and Customs Compliance, Drug Precursor, and Distilled Spirits Plant Compliance. We reduce risk and help protect our client’s business by guiding and partnering with them to solve challenging compliance issues. 

For more information about GCSG: http://www.globalcompliancesg.com/about-us

Follow us online:

·         Facebook – http://www.facebook.com/globalcompliancesg

·         Twitter – https://twitter.com/GCSGLLC

·         LinkedIn – https://www.linkedin.com/company/global-compliance-solutions-group-llc

Signup for our monthly global compliance news update email: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

WEF Publishes 2019 Regional Risks for Doing Business Report

On October 1, 2019 the World Economic Forum (“WEF”) published their 2019 Regional Risks to Doing Business Report (the “Report”).(1) The Report “offers a business perspective on the impact of global risks and illustrates how they are experienced differently in each region.”(1)

The Report tracks five risk categories using their Executive Opinion Survey and Global Risks Perception Survey. The only category of risk that ranked in the top 5 from both sets of respondents was technological risks. Cyber-attacks were listed as the most pressing risk for CEO’s in Europe and North America and in six of the 10 largest economies.

Based on data from the Report the top 10 business risks of highest concern globally are:

  1. Fiscal crises

  2. Cyber-attacks

  3. Unemployment or underemployment

  4. Energy price shock

  5. Failure of national governance

  6. Profound social instability

  7. Data fraud or theft

  8. Interstate conflict

  9. Failure or critical infrastructure

  10. Asset bubble

Top ten business risks listed by respondents in East Asia and the Pacific:

  1. Natural catastrophes

  2. Cyber-attacks

  3. Interstate conflicts

  4. Fiscal crises

  5. Extreme weather events

  6. Asset bubble

  7. Data fraud or theft

  8. Energy price shock

  9. Unemployment or underemployment

  10. Failure of national governance

Top ten business risks listed by respondents in Eurasia:

  1. Profound social instability

  2. Interstate conflict

  3. Energy price shock

  4. Fiscal crises

  5. Unmanageable inflation

  6. Failure of financial mechanism or institution

  7. Data fraud or theft

  8. Unemployment or underemployment

  9. State collapse or crisis

  10. Illicit trade

Top ten business risks listed by respondents in Europe:

  1. Cyber-attacks

  2. Asset bubble

  3. Interstate conflict

  4. Energy price shock

  5. Fiscal crises

  6. Data fraud or theft

  7. Failure of national governance

  8. Unemployment or underemployment

  9. Large-scale involuntary migration

  10. Profound social instability

Top ten business risks listed by respondents in Latin America and the Caribbean:

  1. Failure of national governance

  2. Profound social instability

  3. Unemployment or underemployment

  4. Fiscal crises

  5. Failure of critical infrastructure

  6. State collapse or crisis

  7. Illicit trade

  8. Energy price shock

  9. Data fraud or theft

  10. Large-scale involuntary migration

Top ten business risks listed by respondents in North America:

  1. Cyber-attacks

  2. Data fraud or theft

  3. Terrorist attacks

  4. Critical information infrastructure breakdown

  5. Failure of critical infrastructure

  6. Fiscal crises

  7. Failure of national governance

  8. Failure of climate-change adaptation

  9. Extreme weather events

  10. Natural catastrophes

Top ten business risks listed by respondents in South Asia:

  1. Water crises

  2. Terrorist attacks

  3. Man-made environmental catastrophes

  4. Failure of urban planning

  5. Energy price shock

  6. Deflation

  7. Unemployment or underemployment

  8. State collapse or crisis

  9. Fiscal crises

  10. Asset bubble

For additional regions download the Report at the link provided below.

References

  1. WEF - “Regional Risks for Doing Business 2019

UK Serious Fraud Office Issues Corporate Co-operation Guidance

On August 16, 2019 the United Kingdom’s Serious Fraud Office (SFO) posted their Corporate Co-operation Guidance (the “Guidance”)(1). The Guidance makes it clear that co-operation(2) “will be a relevant consideration in the SFO’s charging decisions to the extent set out in the Guidance on Corporate Prosecutions(3) and the Deferred Prosecution Agreements Code of Practice(4).”(1)

However, after laying out the potential for co-operation the Guidance makes it clear that “even full, robust cooperation”(1) does not guarantee an outcome and that each case will be determined separately. The Guidance lists a few indicators that would indicate a co-operating organization, including:

  • Preserving and providing material;

  • Providing witness accounts; and

  • Compliance with compulsory processes initiated by the SFO

    • Guidance with a compulsory process by itself is not sufficient to indicate co-operation.

Additional Details

Preserving and providing material would include, but is not limited to the following:

  • Good general practices - which includes, but is not limited to, preservation of both digital and hard copy relevant material, obtaining and providing material promptly, providing material in a useful and structured manner, etc;

  • Providing digital evidence in a format the SFO requests, creating and maintaining an audit trail for digital evidence and devices, alerting the SFO to relevant material that cannot be accessed by the organisation, preserving passwords, decryption keys, etc;

  • Creating an audit trail for hard copy evidence;

  • Providing relevant financial records and money flows, creating an audit trail for handling of financial material, etc.;

  • Providing industry knowledge, context, and common practices; and

  • Identifying potential witnesses, making employees available, and disclosing documents shown to the employees.

Organizations seeking co-operation credit should provide all witness accounts including any recording, notes and/or transcripts of interviews and identify competent witnesses. An organization will not be penalized for not waiving privilege, but a valid privilege claim must be established.

Guidance on establishing a “valid privilege claim” requires the organization to “provide certification by independent counsel that the material in question is privileged.(1)” It’s important to note that while the organization will not be penalized for refusing to waive privilege the Guidance states that the organization will not be able to take advantage of the “corresponding factor(5) against prosecution that is found in the DPA Code”.

Contact the professionals at GCSG for more information on this development.

References

  1. UK SFO - “Corporate Co-operation Guidance” - 16/08/2019

  2. Co-operation means providing assistance to the SFO that goes above and beyond what the law requires. It includes: identifying suspected wrong-doing and criminal conduct together with the people responsible, regardless of their seniority or position in the organisation; reporting this to the SFO within a reasonable time of the suspicions coming to light; and preserving available evidence and providing it promptly in an evidentially sound format.(1)

  3. UK - “Guidance on Corporate Prosecutions

  4. UK - “Deferred Prosecution Agreements Code of Practice” (DPA Code)

  5. DPA Code: paragraph 2.8.2(i) - “Co-operation: Considerable weight may be given to a genuinely proactive approach…Co-operation will include identifying relevant witnesses, disclosing their accounts and the documents shown to them. Where practicable it will involve making the witnesses available for interview when requested. It will further include providing a report in respect of any internal investigation including source documents. “(4)

Costa Rica's New Anti-Corruption Law

On June 6, 2019 the Costa Rican Legislative Assembly approved a new anti-corruption law(1). The law is the result of efforts(2) by Costa Rica to join the Organization for Economic Cooperation and Development (OECD)(3). To further their efforts, Costa Rica approved the adoption of the OECD “Convention on Combating Bribery of Foreign Public Officials in International Business Transactions” on May 10, 2017(4,5).

Highlights of the new law:

  • Allows for holding domestic (private or state owned) or foreign corporations (conducting business in Costa Rica), trusts, associations, and foundations criminally responsible for domestic or transnational bribery

  • Allows for sanctioning a parent company for the actions of their subsidiaries and affiliates

  • Establishes large potential financial penalties for corporations found guilty of corruption

  • Allows for the potential reduction of penalties (up to 40%) if certain “mitigating circumstances” are met by the corporation

Mitigating Circumstances include:

  • Having in place an effective anti-corruption program

  • Having in place an independent compliance officer

  • Reporting potential non-compliance

  • Cooperation with authorities investigating the potential non-compliance

Costa Rica Corruption Rankings

  • 2018 TRACE Bribery Risk Matrix Rank(6): 48 out of 200 countries (1 Best)

  • 2018 Corruption Perceptions Index Rank(7): 48 out of 180 countries (1 Best)

  • 2019 GCSG Country Compliance “Corruption” Risk Rating(8): Moderate

Contact us to learn more about this development in Costa Rica.

References

  1. Legislative Assembly of the Republic of Costa Rica - “Liability of Legal Persons in Domestic Bribery, Transnational Bribery and Other Crimes” - Legislative Decree No. 9699, Record No. 21,248 | Approved 06/06/2019

  2. OECD - “OECD establishes roadmap for membership with Costa Rica” - 15/07/2015

  3. OECD Home page - “Organization for Economic Cooperation and Development

  4. FCPAmericas Blog - “Costa Rica Adopts the OECD Anti-Bribery Convention” - 06/06/2017

  5. OECD - “Costa Rica to join the OECD Anti-Bribery Convention” - 31/05/2017

  6. Trace International, Inc. - “2018 TRACE Bribery Risk Matrix

  7. Transparency International - “2018 Corruption Perceptions Index

  8. Global Compliance Solutions Group LLC (GCSG) - “Country Risk Ranking - Sources & Methodology

GCSG issues Indonesia country risk profile

Global Compliance Solutions Group LLC (GCSG) issues Indonesia country compliance risk profile

GCSG distributes Indonesia, our third country compliance risk profile – our risk profiles provide business, compliance, and risk professionals with a snapshot of relevant governance, trade compliance, and anti-bribery and corruption risks

PRAIRIEVILLE, LA – GCSG, a professional compliance management consulting company, today issues Indonesia our third country compliance risk profile (“risk profiles”).  The risk profiles are intended for business, compliance and risk professionals concerned with governance, trade compliance, and anti-bribery and corruption compliance risks in countries in which they do business. 

Each risk profile is designed to provide a snapshot of a targeted set of compliance risks within each country to assist the user with understanding the risks in that country as they look to diversify their supply chains, acquire a new business, or improve their knowledge of a country they currently operate within. 

We are excited to build on our client focused services with the launch of our free country compliance risk profiles because we believe they will bring value to the user,” said Jonathan Mellard, Founder, GCSG. 

Each risk profile provides a concise view of relevant legislation, risks, and the current environment.  Every risk profile incorporates a risk ranking for each category and for the country overall.  The risk ranking is determined using our proprietary country risk-scoring tool that analyzes a combination of publicly available factors and then calculates and assigns a score for potential risk at the country level.   

Our first two profiles were Vietnam and Myanmar. Interested parties should periodically check our country risk profiles web page as we continue, over time, to add more profiles.

Access our Indonesia risk profile: http://www.globalcompliancesg.com/s/Indonesia-Country-Risk-Profile-sjh3.pdf

Access our country risk profiles web page: http://www.globalcompliancesg.com/country-risk-profiles

** *** **

Global Compliance Solutions Group LLC

Global Compliance Solutions Group LLC (GCSG) is headquartered in Louisiana, USA.  We provide international Advisory, Audit, and Due Diligence products and services wherever our clients are located across a range of industries in the areas of Anti-Bribery and Corruption, Import, Export, and Customs Compliance, Drug Precursor, and Distilled Spirits Plant Compliance. We reduce risk and help protect our client’s business by guiding and partnering with them to solve challenging compliance issues. 

For more information about GCSG: http://www.globalcompliancesg.com/about-us

Follow us online:

·         Facebook – http://www.facebook.com/globalcompliancesg

·         Twitter – https://twitter.com/GCSGLLC

·         LinkedIn – https://www.linkedin.com/company/global-compliance-solutions-group-llc

Signup for our monthly global compliance news update email: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

GCSG issues Myanmar country risk profile

Global Compliance Solutions Group LLC (GCSG) issues Myanmar country compliance risk profile

GCSG distributes Myanmar, our second country compliance risk profile – our risk profiles provide business, compliance, and risk professionals with a snapshot of relevant governance, trade compliance, and anti-bribery and corruption risks

PRAIRIEVILLE, LA – GCSG, a professional compliance management consulting company, today issues our second country compliance risk profile (“risk profiles”).  The risk profiles are intended for business, compliance and risk professionals concerned with governance, trade compliance, and anti-bribery and corruption compliance risks in countries in which they do business.  Our second profile is for Myanmar.   

Each risk profile is designed to provide a snapshot of a targeted set of compliance risks within each country to assist the user with understanding the risks in that country as they look to diversify their supply chains, acquire a new business, or improve their knowledge of a country they currently operate within. 

We are excited to build on our client focused services with the launch of our free country compliance risk profiles because we believe they will bring value to the user,” said Jonathan Mellard, Founder, GCSG. 

Each risk profile provides a concise view of relevant legislation, risks, and the current environment.  Every risk profile incorporates a risk ranking for each category and for the country overall.  The risk ranking is determined using our proprietary country risk-scoring tool that analyzes a combination of publicly available factors and then calculates and assigns a score for potential risk at the country level.        

Our first profile, issued last week was for Vietnam. Interested parties should periodically check our country risk profiles web page as we continue, over time, to add more profiles.

Access our Myanmar risk profile: http://www.globalcompliancesg.com/s/Myanmar-Country-Risk-Profile-zt2c.pdf

Access our Vietnam risk profile: http://www.globalcompliancesg.com/s/Vietnam-Country-Risk-Profile-kkph.pdf

Access our country risk profiles web page: http://www.globalcompliancesg.com/country-risk-profiles

** *** **

Global Compliance Solutions Group LLC

Global Compliance Solutions Group LLC (GCSG) is headquartered in Louisiana, USA.  We provide international Advisory, Audit, and Due Diligence products and services wherever our clients are located across a range of industries in the areas of Anti-Bribery and Corruption, Import, Export, and Customs Compliance, Drug Precursor, and Distilled Spirts Plant Compliance. We reduce risk and help protect our client’s business by guiding and partnering with them to solve challenging compliance issues. 

For more information: http://www.globalcompliancesg.com/about-us

Follow us online:

·         Facebook – http://www.facebook.com/globalcompliancesg

·         Twitter – https://twitter.com/GCSGLLC

·         LinkedIn – https://www.linkedin.com/company/global-compliance-solutions-group-llc

Signup for our monthly global compliance news update email: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

GCSG launches new country risk profiles

Global Compliance Solutions Group LLC (GCSG) launches new country compliance risk profiles

GCSG distributes Vietnam, their inaugural country compliance risk profile – our risk profiles provide business, compliance, and risk professionals with a snapshot of relevant governance, trade compliance, and anti-bribery and corruption risks

PRAIRIEVILLE, LA – GCSG, a professional compliance management consulting company, today announces the launch of our new country compliance risk profiles (“risk profiles”).  The risk profiles are intended for business, compliance and risk professionals concerned with governance, trade compliance, and anti-bribery and corruption compliance risks in countries in which they do business.  Our first profile, being launched today is for Vietnam.   

In today’s global compliance environment, it can seem like an impossible task for business, compliance, and risk professionals to stay up to date with all the changes.  Amid this fast-paced environment and the recent trade wars some companies are looking to diversify their supply chains and others to grow through acquisition.  We deliberated how we could bring additional value for companies in these situations and decided on a free standardized country-level risk profile.  This approach will enable users to access our in-house and global partner network knowledge without having to formally engage us.  And then, as needed we can provide direct client support with our international advisory, audit and due diligence products and services,” said Jonathan Mellard, Founder, GCSG.

Each risk profile is designed to provide a snapshot of a targeted set of compliance risks within each country to assist the user with understanding the risks in that country as they look to diversify their supply chains, acquire a new business, or improve their knowledge of a country they currently operate within. 

Each risk profile provides a concise view of relevant legislation, risks, and the current environment.  Some risk profiles are drafted solely in-house and others are drafted in collaboration with our global network.  Every risk profile incorporates a risk ranking for each category and for the country overall.  The risk ranking is determined using our proprietary country risk-scoring tool that analyzes a combination of publicly available factors and then calculates and assigns a score for potential risk at the country level.        

We are excited to build on our client focused services with the launch of our free country compliance risk profiles because we believe they will bring value to the user,” added Mellard. 

Interested parties should periodically check our country risk profiles web page as we continue, over time, to add more profiles.

Access our Vietnam country compliance risk profile: http://www.globalcompliancesg.com/s/Vietnam-Country-Risk-Profile-njg4.pdf

Access our country risk profiles web page: http://www.globalcompliancesg.com/country-risk-profiles

** *** **

Global Compliance Solutions Group LLC

Global Compliance Solutions Group LLC (GCSG) is headquartered in Louisiana, USA.  We provide international Advisory, Audit, and Due Diligence products and services wherever our clients are located across a range of industries in the areas of Anti-Bribery and Corruption, Import, Export, and Customs Compliance, Drug Precursor, and Distilled Spirts Plant Compliance. We reduce risk and help protect our client’s business by guiding and partnering with them to solve challenging compliance issues. 

For more information: http://www.globalcompliancesg.com/about-us

Follow us online:

·         Facebook – http://www.facebook.com/globalcompliancesg

·         Twitter – https://twitter.com/GCSGLLC

·         LinkedIn – https://www.linkedin.com/company/global-compliance-solutions-group-llc

Signup for our monthly global compliance news update email: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Revised OFAC Rule Requires Rejected Transaction Reporting | OFAC

On June 21, the Department of the Treasury’s Office of Foreign Assets Control issued an interim final rule that included, among others, new requirements for all US Persons to file reports on rejected transactions. In the past the requirement to report on rejected transactions only applied to financial institutions that rejected a “funds transfer” where processing the transaction may violate OFAC’s rule. (Click here for the article) - USA

China Tariffs Working - Time for Trade Deal is Now or Never | USA Today

“With each passing week, we get more news that China’s economy is under pressure from U.S. tariffs. Growth is slowing, production has faltered and consumers are pulling back. It’s exactly the leverage President Donald Trump hoped to create to bring China to the table, and it’s time his negotiating team delivers results.” (Click here for the article) - USA, China

US Names Nigerians in Massive Fraud Investigation | BBC

“The US authorities have charged 80 people, "most of whom are Nigerian nationals", with participating in a conspiracy to steal millions of dollars, prosecutors say.” (Click here for the article) - USA, Nigeria

EU Launching New Money Laundering Blacklist | Quartz

“The EU is launching a new money laundering blacklist after it’s last one was nixed for naming Saudi Arabia.” (Click here for the article) - Europe, Saudi Arabia, British Virgin Islands, Cayman Islands

Palpinia Merger Creates World’s Second Largest Airfreight Forwarder | Air Cargo News

“DSV has announced that its acquisition of Panalpina will finally be completed today in a deal worth $5.5bn. The combined company will be recognized as DSV Panalpina and the merger will result in the creation of the second-largest airfreight provider in the world – DHL currently leads the pack.” (Click here for the article) - Global

EU and Mercosur Agree Huge Trade Deal After 20 Year Talks | BBC

“EU Commission chief Jean-Claude Juncker said it was the EU's biggest deal to date and, at a time of trade tensions between the US and China, showed that "we stand for rules-based trade. Brazil's President Jair Bolsonaro said it was "historic" and "one of the most important trade deals of all time". (Click here for the article) - Europe, Mercosur

Organic Food Fraud: 4 Farmers to be Sentenced for Misleading Organic Buyers | CBS

“Four Midwestern farmers are scheduled to be sentenced for cheating organic food buyers—the largest fraud scheme of its kind in U.S. history.” (Click here for the article) - US

New York Privacy Act Would be Tougher Than California Bill | CPO Magazine

“Just as legal experts have been predicting for nearly a year, individual U.S. states are starting to develop their own privacy legislation similar in form and content to the California Consumer Privacy Act. The first state to follow the lead of California is New York State, which has proposed new privacy legislation that would be considerably tougher than California’s bill.” (Click here for the article) - US

Revised OFAC Rule Requires Rejected Transaction Reporting

On June 21, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)(1) issued an interim final rule(2) that included, among others, new requirements for all US Persons to file reports on rejected transactions. In the past the requirement to report on rejected transactions only applied to financial institutions that rejected a “funds transfer” where processing the transaction may violate OFAC’s rules.

Reports on Rejected Transactions

The rule revises § 501.604(3) to:

  • Clarify that the section applies to all rejected transactions (not only to rejected funds transfers)

    • OFAC replaced references to “rejected fund transfers” with references to “rejected transactions” and added a definition for the term “transactions”

    • The term transaction includes transactions related to wire transfers, trade finance, securities, checks, foreign exchange, and goods or services(3);

  • Provide additional details around the information that should be provided to OFAC in connection with reports on rejected transactions;

  • Provide guidance on where/how to report the information on rejected transactions; and

  • Make other technical and conforming changes.

Other Revisions

  • Revising § 501.603(4) to provide more detail regarding information to be reported in connection with blocking reports;

  • Revising § 501.801(5) to include information regarding OFAC’s electronic license application procedures; and

  • Other technical and conforming changes to § 501.602(6), § 501.701(7), and § 501.806(8).

The interim final rule was effective on June 21, 2019 and comments were allowed to be submitted until July 22, 2019.

Contact our Advisory team to learn more about this rule change.

References

  1. US Department of the Treasury - Office of Foreign Assets Control

  2. 84 FR 29055-29062

  3. 31 CFR 501.604

  4. 31 CFR 501.603

  5. 31 CFR 501.801

  6. 31 CFR 501.602

  7. 31 CFR 501.701

  8. 31 CFR 501.806

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Wells Fargo Manager Pleads Guilty to $14 Million Fraud Scheme | NBC

“A former Wells Fargo bank manager pleaded guilty Monday for his part in a money laundering, tax fraud and identity theft scheme that led to $14 million in bogus tax refunds, federal prosecutors said.” (Click here for the article) - USA

PACCAR Settles $1.7 Million of OFAC Penalty for DAF Misstep | Freightwaves

“The Treasury Department’s Office of Foreign Assets Control on Aug. 6 announced a $1.7 million settlement agreement with Bellevue, Wash.-based PACCAR to settle allegations that the truck maker’s European subsidiary illegally engaged in the sale of 63 trucks from Europe to Iran between October 2013 and February 2015.” (Click here for the article) - USA, Netherlands, Germany, Bulgaria

FBI Targets Johnson & Johnson, Siemens, GE, in Brazil Graft Cases | CNBC

“The FBI is investigating corporate giants Johnson & Johnson, Siemens, General Electric, and Philips for allegedly paying kickbacks as part of a scheme involving medical equipment sales in Brazil, two Brazilian investigators have told Reuters.” (Click here for the article) - USA, Brazil

China Devalues Currency, Halts Purchases of US Agricultural Products, Threatens Additional Tariffs | Miller Proctor Law

“China’s Ministry of Commerce suspended purchases of U.S. agricultural products, lowered the value of its currency and indicated that it may impose import tariffs on U.S. agricultural products. China’s escalation of the trade conflict with the United States is in response to the Trump Administration’s announcement last week that 10% tariffs would be imposed on all remaining Chinese-origin goods exported to the United States (valued at roughly $300 billion).” (Click here for the article) - USA, China

US Expands Sanctions Against Venezuela Into an Embargo | Wall Street Journal

“The Trump administration imposed a total economic embargo against the government of Venezuela, a significant escalation of pressure against the regime of President Nicolás Maduro and countries including Russia and China that continue to support him, a senior administration official said.)” (Click here for the article) - USA, Venezuela, Russia, China

Bill Seeks to Capture the Demand Side of Foreign Bribery | FCPA Professor

“The Foreign Corrupt Practices Act only captures one participant in a bribery scheme (the so-called supply side) in what is nearly always a two participant scheme. For more on this dynamic, see this recent FCPA Flash podcast episode with Tom Firestone (Baker & McKenzie) for how the demand side of bribery can be best addressed from a legal and policy perspective.” (Click here for the article) - USA

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

China’s #2 Auditor Accused of Faking Data; Client’s IPOs Halted | Yicai Global

“China's securities regulator has suspended 43 initial public offerings and refinancing cases being handled by the country's second-largest accounting firm, including IPOs on the country's new Nasdaq-style trading venue, as the company is probed for allegedly falsifying information.” (Click here for the article) - China

Trump Administration, Democrats Make Progress on New NAFTA | AP News

“Congressional Democrats appear to be moving from “no way” to “maybe” on President Donald Trump’s rewrite of a trade pact with Canada and Mexico.” (Click here for the article) - US, Canada, Mexico

Increase in Trade Circumvention Practices to Evade US Tariffs on Chinese Imports | Resilience 360

“Over recent weeks, several alleged cases of trade circumvention by foreign companies, mostly believed to be from China, have been reported in Vietnam and Cambodia. These companies are allegedly transshipping and re-routing exported goods through third-party countries in a bid to evade U.S. tariffs during a period of ongoing trade tensions between the United States and China.” (Click here for the article) - US, China, Cambodia, Vietnam

Chinese Billionaire Indicted on Charges of Evading Nearly $2 Billion in Tariffs | Wall Street Journal

“A powerful Chinese billionaire has been indicted by a federal grand jury on charges that he evaded nearly $2 billion in tariffs as part of a conspiracy to smuggle massive quantities of aluminum into the U.S.” (Click here for the article) - US, China, Mexico

ICC Announces Launch Date for Incoterms® 2020 | ICC

“The International Chamber of Commerce (ICC) will release Incoterms® 2020 in early September 2019, providing certainty and clarity to businesses trading across borders everywhere.” (Click here for the article) - Global

Inside the Lose-Lose Trade Fight Between Japan and South Korea | Nikkei Asian Review

“As Japan’s controls on chemical exports threaten South Korea’s high-tech sector, politicians and businesses are digging in for the long haul.” (Click here for the article) - Japan, South Korea, US, China

Trump Announces 10% Tariffs on $300 Billion of Chinese Goods | Nikkei Asian Review

“U.S. President Donald Trump said Thursday that he will impose additional 10% tariffs on $300 billion worth of Chinese imports starting Sept. 1, blaming Beijing's foot-dragging on agricultural purchases and other promises made during previous negotiations.” (Click here for the article) - US, China

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

The Only Way to End Corruption in Laos | The Diplomat

“Is Laos’ ruling communist party building up to an anti-corruption campaign similar to the ones we’ve seen in China and Vietnam? Since Prime Minister Thongloun Sisoulith came to power in early 2016, more officials have been dismissed because of graft, and new laws created to tackle it.” (Click here for the article) - Laos, China, Vietnam

US Nonprofit Takes on Corruption in Middle East | Inside Sources

“The Global Justice Foundation hopes to improve global business ethics, specifically in countries where government officials and business leaders engage in illegal activities to create an uneven playing field in the marketplace.” (Click here for the article) - Global

Switzerland to Tighten Anti-Money Laundering Rules | OCCRP

“Known for the banking secrecy that has given the country its reputation as a “dirty money hub,” Switzerland now plans to tighten its anti-money laundering regulations and bring them in line with international standards.” (Click here for the article) - Switzerland

Justice Department to Open Broad New Anti-Trust Review of Big Tech Companies | Wall Street Journal

“The Justice Department is opening a broad antitrust review into whether dominant technology firms are unlawfully stifling competition, adding a new Washington threat for companies such as Facebook Inc., Google, Amazon.com Inc. and Apple Inc.” (Click here for the article) - United States

Malta’s Anti-Money Laundering Regime Fails Final Moneyval Review | KYC360

“Malta’s anti-money laundering regime has failed a review by international experts and the island now has a year to get its house in order or face potential blacklisting procedures.” (Click here for the article) - Malta

It’s All About Relationships with Freight Brokers | Global Trade Magazine

“…When it comes to freight brokers – the licensed intermediaries who work to connect carriers and manufacturers – the ability to run a successful operation relies on a foundation of business relationships.” (Click here for the article) - Global

Vietnam Cracks Down on Tariff Export Detours | Nikkei Asian Review

“The Vietnamese government has begun taking steps to clamp down on shipments of products from China and elsewhere that pass through Vietnam and are relabeled as Vietnamese to avoid U.S. tariffs.” (Click here for the article) - Vietnam, China, United States

US Sanctions Compliance Fines Hit Decade High | Wall Street Journal

“Fines issued by the U.S. regulator enforcing sanctions compliance have hit a decade high at a time when the Trump administration is increasingly using sanctions as a foreign policy tool.” (Click here for the article) - Global

US DOJ Antitrust Division Announces New Policy to Incentivize Compliance

On Thursday, July 11 the US Department of Justice - Antitrust Division(1) announced(2) a new policy that will incentivize companies to implement antitrust compliance programs. The new policy allows prosecutors to consider compliance during the charging and sentencing stage in a criminal antitrust investigation.

The Justice Manual(3) previously stated that “credit should not be given at the charging stage for a (antitrust) compliance program.” The Division has now revised it’s manual and published a guidance document(4) that outlines what prosecutors should look for when they evaluate antitrust compliance programs.

Guidance Document Summary

  • The guidance document focuses on “the evaluation of compliance programs in the context of criminal violations of the Sherman Act such as price fixing, bid rigging, and market allocation”.(4)

  • The guidance was developed based on the Antitrust Division’s own experience and expertise, other resources within the DOJ, the Criminal Division’s guidance on Corporate Compliance Programs(5), and the US Sentencing Guidelines(6) evaluation of effective compliance programs (U.S.S.G. § 8B2.1).

  • The guidance document states that “a truly effective antitrust compliance program gives a company the best chance to obtain the significant benefits available under the Division’s Corporate Leniency program(7).”(4)

  • The evaluation of a company’s compliance program is only one of many other important factors that are considered during charging and sentencing. When prosecutors decide whether to bring criminal charges they must consider the Principles of Federal Prosecution and the Principles of Federal Prosecution of Business Organizations(8).

  • Division prosecutors recognize that the size of the company affects the resources that can be allocated to antitrust compliance and the extent of their antitrust compliance program.

Key Questions

There are three overarching questions prosecutors will ask themselves, when evaluating the effectiveness of a compliance program, at the time of an offense and at the time of a charging decision(4,8):

  • Is the program well designed?

  • Is the program effectively implemented (or applied earnestly and in good faith)?

  • Does the compliance program actually work in practice?

Preliminary questions that a prosecutor will ask when evaluating the effectiveness of a corporations antitrust compliance program include:

  • Does the company’s compliance program address and prohibit criminal antitrust violations?

  • Did the antitrust compliance program detect and facilitate prompt reporting of the violation?

  • To what extent was a company’s senior management involved in the violation?

Elements of an Effective Compliance Program

Factors that prosecutors should consider when evaluating the effectiveness of an antitrust compliance program include (click here to access the guidance document to read all questions evaluated for each factor listed below):

  • The design and comprehensiveness of the program

    • The Justice Manual requires prosecutors to evaluate whether or not a compliance program is a paper program or one that has been effectively implemented.

  • The culture of compliance within the company

  • Responsibility for, and resources dedicated to, antitrust compliance

    • Are there compliance personnel dedicated to compliance responsibilities?

  • Antitrust risk assessment techniques

    • What information or metrics has the company collected and used to help detect antitrust violations?

  • Compliance training and communication to employees

    • How has the company communicated its antitrust policies and procedures to all employees?

    • Are antitrust policies and procedures included in the company’s Code of Conduct?

  • Monitoring and auditing techniques, including continued review, evaluation, and revision of the compliance program

    • An effective compliance program includes monitoring and auditing functions to ensure that employees follow the compliance program.”(4)

    • What monitoring or auditing mechanisms does the company have in place to detect antitrust violations?

  • Reporting mechanisms

    • Is there a publicized system in place whereby employees may report or seek guidance about potentially illegal conduct?

  • Compliance incentives and discipline

    • Also relevant to an antitrust compliance program’s effectiveness are the systems of incentives and discipline that ensure the compliance program is well-integrated into the company’s operations and workforce.”(4)

  • Remediation methods

    • Early detection and self-policing are hallmarks of an effective compliance program and frequently will enable a company to be the first applicant for leniency under the Division’s Corporate Leniency Policy.”(4)

Contact us to learn more about the Antitrust Divisions guidance and to find out how GCSG’s Advisory and Audit teams can guide and partner with you to reduce your antitrust compliance risk and help to protect your company’s bottom line and reputation.

References

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Chinese Bank Involved in Probe | Washington Post

“A U.S. judge has found three large Chinese banks in contempt for refusing to comply with subpoenas in an investigation into North Korean sanctions violations.” (Click here for the article) - United States, China, N. Korea

France Moves Toward US Model in Corp. Led Investigations | Wall Street Journal

“French authorities are encouraging companies to conduct internal investigations when seeking to settle allegations of certain financial crimes—the latest in a series of reforms that brings the country closer to the U.S. model of corporate crime and punishment.” (Click here for the article) - United States, France

Albania’s Self-Consuming Corruption Undermining Path to EU Accession | Emerging Europe

“At a time when Albania was expected to make significant progress in its accession talks with the European Union, some member states are unwilling to support negotiations with Albania and North Macedonia.” (Click here for the article) - Albania, N. Macedonia, France

Biggest Problem Nigeria Faces is Corruption | PM News

“A former aide to President Muhammadu Buhari on Financial Crimes in the Federal Ministry of Justice, Mr. Biodun Aikomo has revealed that “the biggest problem Nigeria faces is corruption, as resources meant for everybody are in the pockets of individuals.” (Click here for the article) - Nigeria

There is a “New Awareness” About Fraud, Corruption - KNZ Finance Head  | The Citizen

“KwaZulu-Natal’s newly appointed head of finance said on Wednesday that government officials were experiencing “a new awareness” when it came to fraud and corruption. MEC Ravi Pillay said there was a “new culture and a new climate” in the country when it came to addressing corruption.” (Click here for the article) - KwaZulu-Natal

African Leaders Launch Landmark 55-nation Trade Zone  | DW News

“It took African countries four years to agree to a free-trade deal in March. The trade zone will unite 1.3 billion people, create a $3.4 trillion economic bloc and usher in a new era of development across the continent.” (Click here for the article) - Africa

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

India - US Trade Conflict | TRADEWIN

“Last year during March, the US Government announced a 25% tariff on steel and a 10% import duty on aluminum products. This move struck the Indian steel industry severely as the US is the seventh largest market for this particular industry. In response, India also proposed to impose duties on goods originating in or exported from the USA in June 2018.” (Click here for the article) - India, United States

US proposes tariffs on another $4 billion of EU goods | American Journal of Transportation

“The U.S. added new products from the European Union to potentially target with retaliatory tariffs in a long-running trans-Atlantic subsidy dispute between Boeing Co. and Airbus SE.” (Click here for the article) - European Union, United States

Customs Value - EU Commission abolishes ‘Domestic Sale’ | Kneppelhout Korthals Lawyers

“…This guidance currently mentions that a ‘domestic sale’, being a sale between a seller and a buyer which are both established in the EU, is not considered a sale for export. This particular guidance is however about to change. The ‘Customs Expert Group on Customs Valuation’ of the EU Commission has recently decided to delete all references to a ‘domestic sale’ from the Guidance Document...” (Click here for the article) - European Union

The Importance of Managing Customs Data Elements Upstream | TRADEWIN

“Like salmon swimming up the river to find a place to spawn, it benefits importers to look at the flow of shipments, ultimately to move upstream to gather relevant data. If you wait until the last minute to get something done, it can feel like a tidal wave of activity coming at you. You may ultimately see delays in the customs clearance of your shipment, for example.” (Click here for the article) - Global

Asia-Pacific: Little to no progress on Anti-Corruption | Transparency International

“With an average score of just 44 for three consecutive years, the Asia Pacific region is making little progress in the fight against corruption. Compared to other regions, Asia Pacific is on par with the Americas (average score: 44) in its lack of progress and behind Western Europe and the European Union (average score: 66).” (Click here for the article) - Global

EU mechanism for trade with Iran now operational | Deutsche Welle

“The European Union announced that its INSTEX mechanism to facilitate trade with Iran was up and running on Friday. France, Germany, and the United Kingdom informed participants that INSTEX had been made operational and available to all EU member states, and that the first transactions are being processed," said an EU statement. INSTEX, which stands for Instrument in Support of Trade Exchanges, is a payment system that will allow companies to trade with Iran despite harsh US sanctions.” (Click here for the article) - European Union, France, Germany, United Kingdom, United States, Iran

US terminates Turkey’s preferential trade agreement, reduced tariffs on steel | Reuters

“The United States on Thursday terminated Turkey’s preferential trade treatment that allowed some exports to enter the country duty free, but it has halved its tariffs on imports of Turkish steel to 25%.” (Click here for the article) - Turkey, United States

Corruption in Africa - The Crisis of our Time? | Africa.com

“Imagine a continent where six of its countries are among the ten countries considered most corrupt in the world, according to Transparency International. Or one where persons empowered by various states to enforce the law, to protect people and property, and to prevent crime and civil disorder are equally as corrupt as the elected representatives of those states. Or think of living in a place where the cost of corruption is higher than the total combined amount of development aid that is received from foreign donors.” (Click here for the article) - Africa

OFAC Publishes a Framework for Compliance

On May 2, 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)(1) published “A Framework for OFAC Compliance Commitments”(2). The publication is intended to provide OFAC’s perspective, to entities subject to US jurisdiction, on what are essential components of an effective sanctions compliance program.

OFAC developed this framework in our continuing effort to strengthen sanctions compliance practices across the boardThis underlines our commitment to engage with the private sector to further promote understanding of, and compliance with, sanction requirements.” - Andrea M. Gacki, Director of the Office of Foreign Assets Control (3)

Summary

  • OFAC continues to emphasize and “strongly encourage” entities subject to U.S. jurisdiction to take a risk-based approach to sanctions compliance by “developing, implementing, and routinely updating a sanctions compliance program (“SCP”).

  • Regardless of company size, sophistication, products/services, geographic locations, etc…each SCP should incorporate at least these five (5) components: management commitment, risk assessment, internal controls, testing and auditing, and training.

  • In enforcement cases, OFAC will evaluate an entities SCP against the Economic Sanctions Enforcement Guidelines (the “Guidelines”)(4) and when applying the Guidelines will favorably consider an entity that had an effective SCP in place at the time a violation occurred.

A Few Key Points

  • Management Commitment

    • Effective senior management commitment, among others, includes providing adequate resources for compliance and support for the authority of compliance personnel within the organization.

    • Adequate resources includes ensuring there are enough personnel with sufficient expertise dedicated to compliance, and adequate information technology, and other resources, as appropriate.

  • Risk Assessment(5)

    • OFAC recommends a risk-based approach to implementation of a SCP and one of the integral components of this approach is to conduct periodic risk assessments.

    • The assessment should include, among others, a review of customers, vendors, products, services, third-party intermediaries, and geographic locations.

  • Internal Controls

    • An effective SCP should include policies and procedures. These policies and procedures should be enforced and updated when weaknesses are detected or requirements change.

    • Sufficient personnel should be appointed to ensure proper integration of the company’s policies and procedures into the daily operation of the company.

    • The organization should clearly communicate their policies and procedures to all relevant staff.

  • Testing and Auditing

    • An effective SCP include’s a comprehensive and objective testing or audit function that identifies program weaknesses and deficiencies.

    • Any deficiencies identified, including software systems, should be addressed.

  • Training

    • An effective training program is considered an integral component of a successful SCP. The training should be provided to all appropriate employees and personnel on a periodic basis (at a minimum, annually).

  • Root Causes of OFAC Compliance Program Breakdowns - OFAC has identified the following common areas where deficiencies resulted in sanctions compliance failures:

    • Lack of a formal OFAC sanctions compliance program;

    • Misinterpreting, or failing to understand the applicability of, OFAC’s regulations;

    • Facilitating transactions by non-US persons (including through or by overseas subsidiaries or affiliates);

    • Exporting or re-exporting US-origin goods, technology, or services to OFAC sanctioned persons or countries;

    • Utilizing the US financial system, or processing payments to or through US financial institutions, for commercial transactions involving OFAC-sanctioned persons or countries;

    • Sanctions screening software or filter failures;

    • Improper due diligence on customers/clients;

    • De-centralized compliance functions and inconsistent application of their SCP; and

    • Utilizing non-standard payment or commercial practices.

Contact us to learn more about OFAC’s guidance and to find out how GCSG’s Advisory and Audit teams can guide and partner with you to reduce your sanctions compliance risk and protect your company’s bottom line and reputation.

References

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Bribes and Backdoor Deals Help Foreign Firms Sell to China’s Hospitals | The New York Times

“A review of dozens of Chinese court cases and internal corporate documents as well as interviews with company insiders showed how foreign firms have become deeply enmeshed in the corruption pervading China’s health care industry.” (Click here for the article) - China, Global

Expedia Settles Alleged Violations of U.S. Sanctions on Cuba | Wall Street Journal

“Expedia Group Inc. agreed to pay more than $325,000 to settle allegations that it violated U.S. sanctions on Cuba, the Treasury Department said.” (Click here for the article) - Cuba, United States

Exploring the causes of persistent corruption | PHYS ORG

“Corruption impedes equitable development, destabilizes societies, and undermines the institutions and values of democracy. It is viewed by many as one of the world's greatest problems. According to a Gallup poll, a majority of people even place its negative impacts ahead of global problems like climate change, poverty and terrorism.” (Click here for the article) - Global

Europol highlights Russian money as biggest laundering threat | Reuters

“Europe's Baltic states are at risk from further Russian money laundering, a top European police official said after several big banks were hit by scandals centred on the region.” (Click here for the article) - Russia, China, Latvia, Lithuania, Estonia

Treasury Sanctions Iran’s Largest Petrochemical Holding Group | U.S. Department of the Treasury

“The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against Iran’s largest and most profitable petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for providing financial support to Khatam al-Anbiya Construction Headquarters (Khatam al-Anbiya), the engineering conglomerate of the Islamic Revolutionary Guard Corps (IRGC).  In addition to PGPIC, OFAC is designating PGPIC’s vast network of 39 subsidiary petrochemical companies and foreign-based sales agents.” (Click here for the article) - Iran, USA

Mexico joins the anti-bribery enforcement bandwagon | The FCPA Blog

“Anti-corruption law has never been thought to hold much sway in Mexican affairs. Despite a nominal prohibition of bribery and graft and an abundance of recent corruption scandals, the country’s history of minimal enforcement has fostered an expectation of impunity...That may no longer be the case. In his successful campaign for office last year, Mexico’s President Lopez Obrador promised an administration that would fight corruption by taking on the “mafias of power” -- politicians and industry magnates who have enriched themselves through dubious federal contracting practices.” (Click here for the article) - Mexico

House begins debate on new NAFTA ratification bill | CTV News

“Members of Parliament began debating the new NAFTA implementation bill in the House of Commons on Tuesday. Foreign Affairs Minister Chrystia Freeland began the debate by extolling the benefits of the deal, saying Canada is ready to ratify the trilateral trade pact, as soon as the U.S. and Mexico are.” (Click here for the article) - Canada, Mexico, US

Vietnam says some Chinese exporters are using fake ‘Made-in-Vietnam’ labels to avoid US tariffs | The Daily Caller

“Some Chinese exporters are putting fake “Made-in-Vietnam'“ stickers to try to avoid U.S. tariffs, Vietnam alleged Sunday.” (Click here for the article) - Vietnam, China, US

India lost over 90,000 crore to trade misinvoicing, says GFI report | livemint

“India lost a staggering $13 billion, over ₹90,000 crore, to trade misinvoicing, equivalent to 5.5% of the value of the country's total revenue collections in 2016, according to a report by the US-based think tank Global Financial Integrity.” (Click here for the article) - India, China

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Chinese Goods Navigate Alternate Trade Routes to US Shores | Nikkei Asian Review

“Higher U.S. tariffs from the trade war with China are altering patterns of world trade as exporters use third countries to bypass the duties, data reveals.” (Click here for the article) - Japan, Vietnam, China, US

As Trade Wars Move to Mexico, Companies Lose a Safe Harbor | New York Times

“When trade tensions with China flared last year, many companies sought refuge in a country with a long, stable relationship with the United States: Mexico.” (Click here for the article) - US, China, Mexico

Historic Africa Free Trade Agreement Enters Into Force | AP News

“African leaders are celebrating the entry into force of a continental free trade agreement that creates what they call the world’s largest trading market of 1.2 billion people.” (Click here for the article) - Africa

Report Shows Counterfeit Trade Increase in 2019 | Global Trade Magazine

“A report released by OECD and the EU’s Intellectual Property Office confirmed that counterfeit and pirated goods in trade reached 3.3 percent this year.” (Click here for the article) - Europe, China

Global Customs and Trade: It’s Relevance and Why You Should Consider Specialists | Harvey John

“In recent years, shifts in regulatory processes, legislation, and the prominent presence of Brexit, has made an increasing impact on how businesses deal with cross-border affairs.” (Click here for the article) - Global

Dispute Resolution along the Belt and Road | East Asia Forum

“The prospect of disputes arising in respect of projects under China’s Belt and Road Initiative has generated considerable interest, accompanied by positioning on the part of governments, government institutions, lawyers and academics who see potential opportunities.” (Click here for the article) - China

US Scientists, Policy Advisors Oppose Restrictions on Collaboration with China | Xinhuanet News

“The recent U.S. moves to throw a wrench into its scientific collaboration with China are "counterproductive" and could "backfire," scientists and policy advisors here have warned.” (Click here for the article) - US, China

Former Workers Arrested for Embezzling Nearly $1M from Mississippi Community College | Fox13

“Two former Coahoma County Community College employees are facing criminal charges after investigators said they embezzled $750,000.” (Click here for the article) - US

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

Guide to the General Data Protection Regulation  | Information Commissioner’s Office

“The Guide to the GDPR is part of our Guide to Data Protection. It is for DPOs and others who have day-to-day responsibility for data protection.” (Click here for the article) - United Kingdom

German Business Down with Iran as US Sanctions Bite | National Post

“A German business group says German companies’ trade with Iran has declined sharply as the United States turns up the economic heat on Tehran.” (Click here for the article) - Germany, Iran, US

Americans Snap Up Imports from Vietnam at China’s Expense | Bloomberg

“Vietnam was one of the fastest-growing sources of American imports from Asia last quarter, and could potentially overtake the U.K. as a bigger supplier to the U.S. if it keeps up that pace.” (Click here for the article) - Vietnam, UK, US, China

Businessman Admits Offenses in Citgo Bribe Case | The FCPA Blog

“An executive who controlled several U.S.-based companies pleaded guilty Wednesday to bribing officials at subsidiaries of Venezuela's state energy company.” (Click here for the article) - US, Venezuela

Trump’s 5% Tariff on Goods Imported from Mexico doesn’t Sit Well with US Businesses | Supply Chain 24/7

“President Trump’s threat to impose across-the-board tariffs on Mexico is stirring widespread opposition and concern among U.S. business groups who say they could have major negative impacts on supply chains and trade activity.” (Click here for the article) - US, Mexico

Southeast Asia Gains New Leverage as China and US Battle for Influence | Asian Review

“There are two "friendship bridges" spanning the Tonle Sap river in the Cambodian capital of Phnom Penh. One is labeled the Cambodia-Japanese friendship bridge; the other is the Cambodia-China friendship bridge. Sitting almost side by side, the bridges are an unintended reflection of the rivalry between Japan and China, in Cambodia and across much of the surrounding Mekong region, where the two countries are the largest donors and investors.” (Click here for the article) - US, China, Cambodia, Japan

Weekly Compliance News - Around the World

GCSG's Weekly Compliance News feature is a compilation of some of the previous weeks interesting trade compliance, anti-bribery and corruption, fraud, and due diligence news bites, from around the world.

The anatomy of a scam: How far fraudsters will go to steal your money  | Ottawa Citizen

“Gone are the days a Nigerian prince would email you, promising untold riches in exchange for a small payment upfront. Today’s scams are more intimate. Fraudsters craft tailored messages and emails; fake identities; real world addresses for not-so-real companies; websites; phone numbers; a significant corporate presence online; multiple email addresses; and even apparent news coverage from reputable sources.” (Click here for the article) - Global, Canada

Why corruption matters in the EU elections  | Transparency International

“Over the next four days, citizens from 28 countries across the European Union (EU) will cast their vote in one of the largest democratic elections worldwide. With 751 seats at stake in the European Parliament and each Member of Parliament (MEP) poised to serve a five-year term, there’s a lot riding on these elections.” (Click here for the article) - European Union

How does someone get scammed into buying $160,000 in gift cards?  | Marketplace Morning Report

“How does someone get scammed into buying $160,000 in gift cards? Nordstrom goes small.” (Click here for the article) - Global

Trade War: What Chinese Entrepreneurs Really Think  | FINEWS ASIA

“As the U.S.-Chinese trade tussle weighs heavily in Asia, what do Chinese entrepreneurs truly think about the conflict? finews.asia asked an Asian family office.” (Click here for the article) - USA, China

How to Demonstrate Your Value as an Anti-Fraud Professional  | ACFE

“The biggest challenge people have when working toward professional advancement is understanding how to communicate the value their expertise and experience can bring to decision-makers. Whether it’s a new job, a promotion, or signing on a new client or customer, the message must be about how your expertise and value solve their problems.” (Click here for the article) - Global

New EU-wide whistle-blower rules approved  | GCSG

“On April 16, the European Parliament voted(1) in favor of adopting new European Union (“EU”) wide standards to protect whistle-blowers. The standards are designed to protect whistle-blowers that reveal breaches of EU law in areas of public procurement, financial services and tax, money laundering, product and transport safety, protection of the environment, food and feed safety, animal health and welfare, nuclear safety, public health, security of network and information systems, competition, consumer and data protection, fraud, corruption and any other illegal activity affecting the use of Union expenditures.” (Click here for the article) - European Union

Top 5 Cyber Security Threats for Executives  | Prescient

“High profile cyber incidents such as massive data breaches have become increasingly common across industries, especially in the past two years. Such events speak to the shift in perception for cyber crimes–from an overlooked and niche concern to a public, major security problem for organizations across industries. Everything from manufacturing, healthcare, and traditionally higher risk sectors such as banking and technology have been privy to such incidents. In the corporate realm, senior executives are primary targets of hackers, fraud and phishing scams due to their high level of access to valuable corporate information.” (Click here for the article) - Global

U.S. Terminates Turkey’s Preferential Trade Agreement, Reduces Tariffs on Steel  | US News & World Report

“The United States on Thursday terminated Turkey's preferential trade treatment that allowed some exports to enter the country duty free, but it has halved its tariffs on imports of Turkish steel to 25%.” (Click here for the article) - USA, Turkey