GCSG Announces the Approval of "GCSG" Trademark

Global Compliance Solutions Group LLC announces “GCSG” trademark approval by the USPTO

GCSG announces as of December 31, 2019 the United States Patent and Trademark Office (USPTO) officially approved our registration for the “GCSG” service mark

PRAIRIEVILLE, LA – GCSG, a professional compliance management consulting company, today announces that on December 31, 2019 the USPTO approved our application and issued a registration for the “GCSG” service mark. The mark consists of standard characters without claim to any particular font style, size or color.

Jonathan Mellard, Founder of GCSG commented, “We at GCSG are delighted to announce the issuance of our “GCSG” trademark. We believe it speaks to the longevity of our company and will help to differentiate us from other companies marketing the terms global compliance or compliance solutions.”

Registration Details

  • Registration No. 5,949,341

  • Class: 45

  • Service Mark

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Global Compliance Solutions Group LLC

GCSG is headquartered in Louisiana, USA.  We provide international Advisory, Audit, and Due Diligence products and services wherever our global 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

Contact

E   info@globalcompliancesg.com

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

US Imposes Additional Sanctions on Iran's Industry

On January 10, 2020 the U.S. President issued an Executive Order(1) establishing additional sanctions on Iran. The new sanctions target the construction, mining, manufacturing, and textile sectors of the Iranian economy.

We are also designating Iran’s largest metals manufacturers, and imposing sanctions on new sectors of the Iranian economy including construction, manufacturing, and mining”(2), said Secretary Steven T. Mnuchin.

The Executive Order blocks the property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any US person of the following:

  • The 13 largest steel and iron manufacturers and the top aluminum and copper companies in Iran including Mobarakeh Steel Company, Saba Steel, Hormozgan Steel Company, Esfahan Steel Company, Oxin Steel Company, Khorasan Steel Company, South Kaveh Steel Company, Iran Allow Steel Company, Golgohar Mining and Industrial Company, Chadormalu Mining and Industrial Company, Arfa Iron and Steel Company, Khouzestan Steel Company and Iranian Ghadir Iron & Steel Company, Iran Aluminum Company, Al-Mahdi Aluminum Corporation, Khalagh Tadbir Pars Co, and the National Iranian Copper Industries.

  • China entities Pamchel Trading Beijing Co Ltd, Hongyuan Marine Co Ltd and Seychelles-based (Power Anchor Limited a front company for Pamchel Trading Beijing Co, Ltd) entities; and a vessel (Hong Xun) involved with Iranian metals products.

  • Oman-based Reputable Trading Source LLC, which is owned or controlled by Khouzestan Steel Company.

  • Senior Iranian officials involved in recent ballistic missile strikes.

In addition, the Secretary of the Treasury is authorized to sanction foreign financial institutions that knowingly conduct or facilitate any significant financial transaction in contradiction to the Executive Order. See the Executive Order for additional restrictions and details.

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

References

  1. Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran - January 10, 2020

  2. US Department of the Treasury Press Release: “Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials” - January 10, 2020

GCSG Issues China Country Risk Profile

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

GCSG distributes China, our fifth 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 China our fifth country compliance risk profile.  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 four profiles were Vietnam, Myanmar, Indonesia, and Malaysia. Interested parties should periodically check our country risk profiles web page as we continue, over time, to add more profiles.

Access the China risk profile: http://www.globalcompliancesg.com/s/China-Country-Risk-Profile_2020.pdf

Access all of our country risk profiles: http://www.globalcompliancesg.com/country-risk-profiles

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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 global 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

Happy New Year 2020 from GCSG!

   The GCSG team wishes you a Happy New Year!  We extend our best wishes to you for a 2020 full of health as well as personal and professional success.

   We owe our success in 2019 to our clients and partners and we are very grateful to you for partnering with GCSG.  We look forward to continuing our successful partnership in 2020!   

   For our clients and vendors make sure to take advantage of our offer, through January 30th, to make a special corporate donation on your behalf to one of the charities listed below.  Send a contact form with just the name of one of the three charities listed below in the subject or body of the form and we will make a donation to the charity you've chosen.   

Happy New Years,

The GCSG Services Team

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Global Compliance Solutions Group LLC (GCSG)

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. 

To learn more 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 newsletter: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

US DOJ Revises Export Control and Sanctions Enforcement Policy

On December 13, 2019 the US Department of Justice (“DOJ”) re-issued a revised Voluntary Self-Disclosure Policy(1) (“VSD Policy”) for export control and sanctions violations. The revised VSD Policy is effective December 13, 2019 and it supersedes prior guidance issued by the US DOJ’s National Security Division in October 2016. The updated VSD Policy will be incorporated into the Justice Manual(2). Three changes from the prior guidance include(3):

  • Provides more clarity on the benefits available to companies that voluntarily self-disclose violations, fully cooperate with the DOJ, and timely and properly re-mediate the issues;

  • Clarifies that disclosures of willful conduct to regulatory agencies and not to DOJ will not qualify for the benefits provided under the VSD Policy; and

  • The definitions(1) of “Voluntary Self-Disclosure”, “Full Cooperation”, and “Timely and Appropriate Remediation” were modified to more closely align with the Departments FCPA Corporate Enforcement Policy.

References

  1. US DOJ - “Export Control and Sanctions Enforcement Policy for Business Organizations” - December 13, 2019

  2. US DOJ - “Justice Manual

  3. US DOJ Press Release - “Department of Justice Revises and Re-Issues Export Control and Sanctions Enforcement Policy for Business Organizations” - December 13, 2019

Merry Christmas from GCSG!

The GCSG team wishes you and yours a happy and safe Christmas holiday season.  We extend our best wishes for a New Year full of promise and success.  

   From now till the end of the year, GCSG will make a special corporate donation on behalf of our clients and other business partners.  We'd like to invite our clients and vendors to choose one of the charities listed below to receive a donation. 

   Send a contact form with just the name of one of the three charities listed below in the subject or body of the form and we will make a donation to the charity you've chosen.   

   This holiday season we are grateful to you for partnering with GCSG, and we look forward to continuing our successful partnership in 2019! 

Merry Christmas,

The GCSG Services Team

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Global Compliance Solutions Group LLC (GCSG)

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. 

To learn more 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 newsletter: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

GCSG Celebrates International Anti-Corruption Day

GCSG will do our part to help fight global corruption as we Celebrate International Anti-Corruption Day

Today, December 9 GCSG celebrates a global day to raise awareness for the fight against corruption

PRAIRIEVILLE, Louisiana, December 9, 2019 – GCSG, a professional compliance management consulting company, focused on helping companies reduce their risk and solve challenging compliance issues celebrates International Anti-Corruption Day.

"Corruption affects every country, region and community. No one is immune to this crime. But everyone can take part in the fight against corruption."(1)

GCSG will do our part to support global anti-corruption efforts by conducting our business in an ethical manner, thereby protecting the integrity of our organization and ensuring no harm to our clients.

Corruption affects people in their daily lives. It bars them from accessing resources and opportunities. It erodes trust in public institutions and compromises the social contract. In doing so, corruption thwarts our attempts at building a better world.”(2)

For more information:

(1http://www.anticorruptionday.org/

(2) http://www.anticorruptionday.org/actagainstcorruption/en/about-the-campaign/ed-message-on-anti-corruption-day-2019.html

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#UnitedAgainstCorruption

#IACD2019

#UNODC

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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. 

To learn more 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 newsletter: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

Happy Thanksgiving from the GCSG Team!

Happy Thanksgiving from GCSG!

GCSG wishes you and your family a happy and safe Thanksgiving holiday!

This Thanksgiving we are thankful for all our clients and vendors and for the many successes we have achieved together this past year!

We are always here to guide and partner with our clients to reduce compliance risk and help protect their bottom line and reputation.  We strive to exceed our clients expectations by providing high quality compliance products and services while staying true to our core values of integrity, service and accountability.

Kindest regards,

GCSG Services Team

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Global Compliance Solutions Group LLC (GCSG)

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. 

To learn more 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 newsletter: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

GCSG launches Compliance Risk Index

GCSG launches inaugural Compliance Risk Index (CRI)  

GCSG introduces CRI, our inaugural compliance risk index – the CRI provides business, compliance, and risk professionals with an easy to understand risk number and rating, at the country-level, that quantifies overall compliance risk across four domains and separately within each of the four domains

PRAIRIEVILLE, LA., Nov. 20, 2019  – GCSG, a professional compliance management consulting company, today announces the launch of our new Compliance Risk Index (CRI).  The CRI measures perceived compliance risk in more than 200 countries.  It provides a calculated overall composite risk number and assigns a composite risk rating across four domains (Governance and Regulatory, Bribery and Corruption, Trade, and Financial) and a score and rating within each domain for each country.    

The domains are assessed using publicly available data sources such as the World Bank, World Economic Forum, and the Heritage Foundation.  Based on our analysis and algorithm the information is processed and a score is assigned.     

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, improve their compliance programs, and others to grow through acquisition.  We deliberated how we could bring additional value for companies in these situations and decided on a no cost annual compliance risk index as well as our recently introduced country risk profiles,”  said Jonathan Mellard, Founder, GCSG.

The CRI is provided to the public at no cost and was developed to be a tool for business, compliance and risk professionals to assist with compliance risk assessments for ongoing operations or M&A activity and to be used as part of a risk-based compliance program. 

“Our compliance risk index and our country risk profiles will enable users to access our knowledge and experience 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,” added Mellard. 

Access our Compliance Risk Index: http://www.globalcompliancesg.com/compliance-risk-index

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

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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. 

To learn more 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 newsletter: http://eepurl.com/crXHmL

Contact

E   info@globalcompliancesg.com

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

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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

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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

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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