The recent headlines on China's expanding anti-corruption investigation and enforcement action is a significant event in global anti-corruption enforcement. For companies operating in China, the risks have now increased…more
The United States spends over $2.81 trillion dollars on health care annually and generates billions of claims from millions of health care service and product providers. The vast majority of these providers of services and…more
With all the hoopla over hiring of relatives of foreign officials, it is important to keep in mind the risks and how the FCPA applies.
The talismanic concept for tan FCPA violation is “corrupt intent.”…more
JP Morgan stands as the poster child for how not to interact and resolve issues with the federal government.
After what appeared to be a difficult set of negotiations, the Justice Department and JP Morgan reached a record…more
Luckily, the Justice Department and SEC’s recent FCPA settlements with Weatherford and Bilfinger do not fall into the Big Lebowski “complicated case” category. They are both examples of cases in which companies suffered…more
As global enforcement becomes a reality, companies face a unique set of risks which can be mind-numbing in complications. With the long-arm reach of the FCPA, UK Bribery Act and other anti-corruption laws, more enforcement…more
The controversy around punishment and deterrence of corporate misconduct continues to swirl. As fines increase against companies, it is important to ask the question whether the current enforcement scheme adequately punishes…more
When it comes to health insurance fraud, Carl Sagan’s obsession with the words – billions and billions — are particularly accurate.
As the government’s role in health care increases, it is inevitable that fraud against…more
One of the many challenges in the compliance profession centers on coordination and integration. There are plenty of compliance experts who can describe a perfect world – how to design a specific program and procedures to…more
Almost every FCPA enforcement action involves violations committed by third-party agents, consultants and distributors. Many companies have instituted due diligence procedures to screen third-parties, consultants and…more
Companies need to recognize the importance of responding effectively to a whistleblower complaint. The Enron case, and many others after that, started with a whistleblower complaint which the company either ignored or bungled…more
There are so many potential pitfalls in conducting an internal investigation. I always say that there is an “art” to conducting an effective internal investigation…more
Everyone knows that a compliance officer does not need to be a lawyer. Some compliance professionals believe that lawyers do not make very good compliance officers – the jury is out on that…more
Just when you thought something was a “trend,” the Department of Justice adopts a new policy approach. This year has been a very active enforcement year – the strongest year of FCPA enforcement since 2010…more
The government recognizes the importance of compliance and Chief Compliance Officers. In a number of recent speeches, the leadership of the Justice Department and the SEC have made important statements supporting corporate…more
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