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Hogan Lovells Global Payments Newsletter l January 2017

Welcome to the Hogan Lovells Global Payments Newsletter. In this monthly publication we provide an overview of the most recent payments, regulatory and market developments from major jurisdictions around the world as well as...more

Compliance into the Weeds-Episode 25 [Video]

In this episode Matt Kelly and I take a deep dive into a couple of recent SEC enforcement actions. The first involved L-3 Technologies and accounting irregularities. The second involves BlackRock and the continued issues...more

Day 15 of 30 Days to a Better Compliance Program-Post Training Evaluation [Video]

What if you want to take you post-training analysis to a higher level and begin to consider the effectiveness through your return on investment (ROI)? Joel Smith, the founder of Inhouse Owl, a training services provider,...more

Day 14 of 30 Days to a Better Compliance Program-Design of Your Compliance Training Program [Video]

For compliance training to be effective its needs to risk-based in its focus. This means employees with highest risk of exposure to bribery and corruption need to receive the highest levels of training and refreshers. From...more

This Week in FCPA-Episode 35-the Friday the 13th edition [Video]

Show Notes for Episode 35, week ending January 13, the Friday the 13th edition   1.       Hernandez and Beech FCPA guilty pleas. 2.       VW guilty plea in emissions-testing scandal. 3.       VW executive Oliver...more

Day 13 of 30 Days to a Better Compliance Program, create a data action plan [Video]

You should work to create an action plan to use your data. But never forget you need to get your digital information right. That means several sources of data to help you choose the best course of action. Earlier this year,...more

Day 12 of 30 Days to a Better Compliance Program, creating a culture of data in compliance [Video]

You should work to create a culture of data in your compliance program. This comes from an understanding that data is a product, which you can consume internally in the compliance function. Your data is a corporate asset so...more

Expect the Unexpected: The Year Ahead for the Financial Institutions Sector

With contributors across the sector and the globe, we've compiled a review of some of the developments that will affect financial institutions in 2017 and beyond. The one thing that 2016 taught us was to expect the...more

Compliance into the Weeds-Episode 24 [Video]

In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he proposes a regulatory scheme for...more

Day 10 of 30 Days to a Better Compliance Program, Mergers and Acquisitions [Video]

A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps, most commonly, inadequate due diligence can allow a course of bribery to continue - with...more

Day 9 of 30 Days to a Better Compliance Program, Continuous Improvement [Video]

No area has become more challenging in compliance than continuous improvement. The FCPA Guidance specifies that “a good compliance program should constantly evolve. A company’s business changes over time, as do the...more

Day 8 of 30 Days to a Better Compliance Program, Reporting and Investigations [Video]

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

Day 7 of 30 Days to a Better Compliance Program, Third Parties [Video]

Day 7- Third-Parties There are five steps in the life cycle of third party management. 1. Business Justification and Business Sponsor; 2. Questionnaire to Third Party; 3. Due Diligence on Third Party; 4. Compliance...more

This Week in FCPA-Episode 34-the Invisible Hand edition [Video]

In this episode Jay Rosen and I take a dive into the General Cable FCPA enforcement action, consider the 'Invisible Hand' of Justice Department Compliance Counsel Hui Chen and greater regulatory enforcement, corporate...more

Day 6 of 30 Days to a Better Compliance Program, Carrots and Sticks [Video]

The FCPA Guidance states, that “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance...more

Day 5 of 30 Days to a Better Compliance Program, Communications and Training [Video]

Welcome to Day 5 of 30 Days to a Better Compliance Program. Today, I focus on training, ongoing communications and the use of social media in a best practices compliance program. Training The communication of your...more

Your Daily Dose of Financial News

The Fed’s anticipating faster growth in the coming year and rate increases to go with it. That and a whole lot of uncertainty about the incoming administration are the big takeaways from the Fed’s December meeting minutes....more

Compliance into the Weeds-Episode 23, Six Compliance Issues to Consider in 2017 [Video]

In this episode, Matt Kelly and I consider six compliance-related issues every compliance practitioner should watch in 2017. ...more

Day 4 of 30 Days to a Better Compliance Program, Risk Assessments [Video]

Welcome to Day 4 of 30 Days to a Better Compliance Program. Today we tackle risk assessments. One cannot really say enough about risk assessments in the context of anti-corruption programs. The FCPA Guidance stated it...more

Your Daily Dose of Financial News

Lynn Tilton’s very public spat with the SEC over the agency’s in-house court system may be heading to the Supreme Court, thanks in part to a recent 10th Circuit opinion last week that created a Circuit split over the...more

Day 3 of 30 Days to a Better Compliance Program, the CCO [Video]

Welcome to Day 3 of 30 Days to a Better Compliance Program. Today I want to consider the Chief Compliance Officer (CCO) in your organization, through three prisms: access, resources and opportunities. Access What...more

Day 2 of 30 Days to a Better Compliance Program, Written Protocols [Video]

Welcome to Day 2 of 30 Days to a Better Compliance Program. Today I consider written protocols, which are the foundation upon which an effective compliance program is built. Written protocols consist of a Code of Conduct,...more

Day 1 of 30 Days to a Better Compliance Program, Tones in an Organization [Video]

Welcome to Day 1 of 30 days to a better compliance program. Together with a podcast each day, I will be giving you tips to help you create a best practices compliance program in 2017. At the end of January, you will not only...more

$519 million FCPA Payment by Teva Pharmaceuticals—Largest Ever FCPA Payment by Pharmaceutical Company—Follows Large FCPA Plea...

On December 22, 2016, the world’s largest manufacturer of generic pharmaceuticals, Teva Pharmaceuticals (“Teva”), agreed to pay $519 million in FCPA-related criminal penalties, disgorgement, and interest. The Israeli company...more

This Week in FCPA-Episode 33-the Holiday Season [Video]

Show Notes for Episode 33, week ending December 23, 2016-Holiday edition 1. Odebrecht/Braskem FCPA enforcement action and its global scope and implications. 2. Goldman Sachs further ensnared in 1MDB scandal-C-Suite level...more

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