Entries by Michael van Woerden

Dutch minister wants judicial review of large ‘transactions’

The Dutch Minister of Justice and Security has announced plans to amend the Dutch Code of Criminal Procedure in response to questions raised by parliament about substantial or extraordinary “transactions”. Transactions are payments agreed between the public prosecutor and a suspect in lieu of criminal prosecution. The plans amend the existing rules on substantial transactions […]

FCPA/Anti-Corruption Developments: 2018 Year in Review

US government enforcement of the Foreign Corrupt Practices Act (FCPA) in 2018 remained robust, and the trend of increasing multi-jurisdictional cooperation and enforcement continued throughout the year. In the United States, the 33 combined individual and corporate FCPA enforcement actions concluded by the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in […]

TI 2018 Progress Report ‘Exporting Corruption’

Transparency International’s 2018 Progress Report is an independent assessment of the enforcement of the Organisation for Economic Co-operation and Development (OECD) Anti-Bribery Convention, which requires parties to criminalise bribery of foreign public officials and introduce related measures. This twelfth such report also assesses enforcement in China, Hong Kong Special Administrative Region of the People’s Republic […]

Compliance Standards & Model Risk

When applying ISO management systems for compliance (ISO 9001), anti-bribery (ISO 37001) and/or similar ‘in control’ tooling with regard to integrity management and business conduct, so called ‘Model Risk’ comes into play. Oversimplification, inappropriate model choice, errors in a model or misuse of a model may lead to the wrong picture, providing comfort in false security only.