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Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks [Video]

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some...more

Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues [Video]

by Thomas Fox on

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more

This Week in FCPA- Episode 52, for the week ending May 12, the Firing the Investigators Edition [Video]

by Thomas Fox on

1. What is the real risk in a FCPA enforcement action? See Mike Volkov’s post in Corruption, Crime and Compliance. 2. FIFA fires its lead internal investigators for doing their job investigating. See Tom’s article in...more

Day 10 Of One Month to Better Compliance through HR-Sales Incentives and Compliance [Video]

by Thomas Fox on

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System –How has the company considered the potential negative compliance...more

Day 8 of One Month to Better Compliance Through HR-Using Compensation to Operationalize Compliance [Video]

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of Justice (DOJ) and Securities...more

Day 7 Of One Month To Better Compliance Through HR - Six Principles For Compliance Incentives [Video]

by Thomas Fox on

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives. She posed it with the following question, “Are there mechanisms to enforce compliance...more

Day 6 of One Month to Better Compliance Through HR-Incentivizing Compliance [Video]

by Thomas Fox on

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – How has the company incentivized compliance and ethical behavior? How has...more

This Week in FCPA-Episode 51, the Cinco De Mayo Edition [Video]

by Thomas Fox on

Show Notes for Episode 51, for the week ending May 5, the Cinco de Mayo Edition Over some breakfast tacos and Mexican coffee, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We...more

Day 4 Of One Month To Better Compliance Through HR-The Hiring Interview As A Step To Operationalize Compliance [Audio]

by Thomas Fox on

One of the theories of conventional wisdom about anti-corruption compliance is that you will never be able to reach 5% of your workforce with compliance training because they are predisposed to lie, cheat and steal anyway....more

Day 3 of One Month to Better Compliance Through HR-JPMorgan Chase FCPA Enforcement Action [Audio]

by Thomas Fox on

Today, I conclude my review of FCPA enforcement actions that involved the corporate hiring function. From these three cases I have considered, it is clear that HR must be involved in compliance and if HR hiring controls are...more

Insider Trading and Related Risks for Executive Branch Employees: Pay Attention to the STOCK Act

by Zuckerman Spaeder LLP on

As a new administration arrives in the nation’s capital amid heightened scrutiny over conflicts between government service and personal business interests, a little-used law — the Stop Trading on Congressional Knowledge Act...more

Everything Compliance-Episode 5, year-end wrap up Part II [Video]

by Thomas Fox on

We turn to the 2016 year in review, in this Part II of a two-part series. Jonathan Armstrong leads a discussion on Privacy Shield, information and data privacy issues the past year. Mike Volkov relates what he saw as the top...more

Everything Compliance-Episode 2 [Video]

by Thomas Fox on

This episode is dedicated exclusively to where FCPA enforcement, SEC enforcement, the compliance profession and compliance programs may be headed under the Trump administration, with a dash of anti-trust enforcement and EU...more

Your daily dose of financial news: The Brief – 6.3.16

by Robins Kaplan LLP on

May’s jobs report is out today, though it may be a slightly less valuable barometer of economic growth due to the Verizon employee strike that wrapped up this week – WSJ Tribune Publishing’s doing more than buoying its...more

Cross-Border Investigations Update - May 2015

In This Issue: - Recent Prosecutions and Settlements: FCPA Enforcement Trends and Developments: Recent U.S. Foreign Corrupt Practices Act enforcement trends include the growing importance of corporate...more

Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

by Shearman & Sterling LLP on

Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action - Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more

DOJ Criminal Division Renews Efforts to Investigate Whistleblower Allegations

by Holland & Knight LLP on

The Department of Justice (DOJ) has signaled a heightened effort to bring criminal prosecutors into the loop regarding False Claims Act referrals and other whistleblower complaints. In recent remarks at a conference comprised...more

Study: Does The Existence Of Whistleblowers In Enforcement Actions Mean Greater Penalties?

According to an academic study published on October 6, 2014 by Andrew C. Hall, Gerald S. Martin, Nathan Y. Sharp, and Jaron H. Wilde, the presence of whistleblowers may have a meaningful impact on the outcomes of enforcement...more

How to Monitor, Audit and Improve Your Anti Corruption Compliance Program [Video]

by Michael Volkov on

Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in...more

Anti-Corruption Due Diligence Practical Steps to Protect Your Company from Third Party Risks [Video]

by Michael Volkov on

Almost every FCPA enforcement action involves misconduct by third party agents and distributors. The Justice Department and the SEC have emphasized the importance of companies conducing appropriate due diligence. In the...more

FCPA Compliance Programs A Review of Best Practices [Video]

by Michael Volkov on

In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices....more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

by Michael Volkov on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Internal Investigations: Soup to Nuts (March 13, 2014) [Video]

by Michael Volkov on

More and more companies need to conduct internal investigations as an important strategy to protect the company against serious government investigations. Not all internal investigations have to be conducted in the same way....more

The Role of a Chief Compliance Officer: Navigating the Compliance Landscape (March 18, 2014) [Video]

by Michael Volkov on

Companies recognize the importance of maintaining effective compliance programs. With the increase in enforcement activity, companies have turned to their Chief Compliance Officers to design and implement effective compliance...more

Designing Cost Effective Risk Assessment Programs May 21, 2014 [Video]

by Michael Volkov on

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure...more

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