Randy Stephens

Randy Stephens

NAVEX Global

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Latest Publications


Building a Better Board Report: Essential Strategies for Chief Compliance Officers

Need to better engage your board—and get buy-in for E&C program investments? Fully leveraging your board reporting opportunity is essential. As compliance professionals, most of us are very proud of the...more

3/2/2015 - Board of Directors Chief Compliance Officers Compliance

Making the Case for Compliance Training for Third Parties

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

2/17/2015 - Chief Compliance Officers Compliance FCPA Risk Mitigation Third-Party Risk Third-Party Service Provider Training

2015 Trends: #5 Regulatory Enforcement Moves Down Market

While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more

1/15/2015 - Bribery Compliance Contractors DOJ Enforcement Actions Enforcement Statistics Ethics FCPA Lawson v FMR Sarbanes-Oxley SCOTUS SEC Small Business Smith & Wesson Subcontractors Whistleblowers

Pinpointing Your International Bribery Risks

In December, the Organization for Economic Cooperation and Development (OECD) released an analysis of all corruption and bribery cases involving the crime of bribery of a foreign public official in international business...more


New False Claims Act Whistleblower Trends Revealed in Recent Verdict: What Can We Learn?

On October 20, 2014 in a case brought by a whistleblower under the False Claims Act (“FCA”), a federal jury handed down a $175 million verdict in favor of the plaintiff. While the outcome was newsworthy because of its size...more

11/19/2014 - Construction Defects Construction Industry False Claims Act Public Projects Qui Tam Whistleblower Awards Whistleblowers

China Bribery Crackdown Underscores the Need for Stronger Compliance Programs and Risk Assessments

Recently, the Chinese government reported that GlaxoSmithKline (GSK) would agree to pay almost $500 million in fines to settle allegations of bribery, and that some former GSK employees would receive prison sentences. While...more

9/25/2014 - Chief Compliance Officers China Compliance Criminal Prosecution FCPA GlaxoSmithKline Reputation Management Risk Assessment Risk Management Settlement UK Bribery Act

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

9/15/2014 - Chief Compliance Officers Compliance Due Diligence Employer Liability Issues FCPA Risk Assessment SEC Securities Exchange Act Smith & Wesson Strategic Enforcement Plan Training

Overheard at the Airport: Material, Non-Public Information

I was recently in a business lounge at the airport in Atlanta, and was amazed to be bombarded by executives on their cell phones loudly conducting business. Sitting within earshot, I learned that a large manufacturer...more

8/22/2014 - Best Management Practices Employer Liability Issues Ethics Insider Trading Privacy Concerns

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

8/13/2014 - Compliance DOJ FCPA Multinationals Risk Assessment SEC Third-Party Risk Training

Bussing v. COR Clearing LLC: What Retaliation Protections Are Whistleblowers Entitled To?

U.S. courts continue to disagree about the extent and coverage of protections from retaliation for “whistleblowers” under the Dodd-Frank Act. Contrary to SEC rules and other District courts, in the 2013 Asadi case, the 5th...more

6/16/2014 - Appeals Chief Compliance Officers Dodd-Frank Employer Liability Issues FINRA Reporting Requirements Retaliation SEC Training Whistleblower Protection Policies Whistleblowers

Esquenazi Appeal Confirms the Broad Reach of the Foreign Corrupt Practices Act (FCPA)

In last month’s closely watched Esquenazi decision, a U.S. court of appeal weighed in on the definition of “instrumentality” under the Foreign Corrupt Practices Act (FCPA) for the first time. The case—an appeal to the 11th...more

6/6/2014 - Appeals FCPA Foreign Entities Foreign Official Instrumentality Popular SEC US v Esquenazi

Senator Delivers Poor Grades to Executive Departments on Whistleblower Protections

A memorandum released yesterday by Senator Charles E. Grassley highlights allegations that 14 of the 15 executive branch departments are in violation of the Whistleblower Protection Enhancement Act (WPEA)....more

4/4/2014 - Whistleblower Protection Policies Whistleblowers

Retaliation Exposure Tipping Point? Supreme Court Extends SOX Whistleblower Protections to Private Company Employees

The Supreme Court in Lawson vs FMR, LLC (delivered March 4, 2014 after a 6-3 vote) has ruled that employees of private companies engaged by public companies are covered by the whistleblower protections of Sarbanes Oxley Act...more

3/10/2014 - Contractors FMR LLC Lawson v FMR Retaliation Sarbanes-Oxley SCOTUS Subcontractors Whistleblower Protection Policies Whistleblowers

Mandatory Training for Third Parties – Effective or Protective?

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

1/10/2014 - Anti-Bribery Compliance DOJ Enforcement Ethics FCPA SEC Supply Chain Third-Party Liability Training

Is the Office of the Whistleblower Living up to its Hype?

2013 Annual Report to Congress on the Dodd-Frank Whistleblower Program - Back when the Dodd-Frank Act first proposed the creation of the Office of the Whistleblower (OWB) a hue and cry went up from chief compliance...more

11/24/2013 - Compliance Dodd-Frank Hotlines Internal Controls Whistleblower Awards Whistleblowers

The FCPA May Have its Flaws, but it is Not Anti-Business

“The U.S. government is too restrictive in trying to prevent its companies from corruption abroad and that’s hurting business expansion in Asia and elsewhere, according to Penn National Gaming Chairman Peter...more

11/15/2013 - Bribery Corruption DOJ Enforcement FCPA SEC

The Compliance and Audit Partnership: Top 3 Risks and Audit Responses

A few days ago, I presented at the 2013 Governance, Risk, and Control Conference in Phoenix, Arizona, and am excited to highlight the growing force Internal Audit plays in partnering with Compliance to establish and implement...more

8/23/2013 - Audits Compliance Corporate Counsel Corporate Governance Internal Investigations

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

8/1/2013 - Audits Bribery Compliance DOJ Due Diligence FCPA Risk Assessment Risk Management Risk Mitigation SEC Third-Party Training

Challenges Abroad: Ensuring Fair Working Conditions for Third Parties

Since Rana Plaza garment factory collapsed in Bangladesh in April, killing 1,100 workers, many retailers have taken a closer look at the working conditions in their third party suppliers’ factories. European retailers like...more

6/12/2013 - Compliance H&M K-Mart Retailers Safety Precautions Suppliers Target Third-Party Working Conditions

The Relationship between Procedural Justice and Resolving Employee Concerns

Today’s Ethics Resource Center (ERC) Fellows Program Survey, Encouraging Employee Reporting through Procedural Justice, noted the effects procedural justice can have on employee support for a hotline/helpline. Some of the...more

5/31/2013 - Hotlines Internal Investigations Reporting Requirements Whistleblowers

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