In the compliance world, lawyers and accountants are strange bedfellows. Sometimes they need each other, and sometimes they do not. Each has advantages and disadvantages. Working together, you get both.
I shudder when I…more
The Middle East is a diverse area with significant disparities in the region. Oil and gas dominate the economies. Cultural and economic factors make compliance extremely difficult in the Middle East.
Interestingly, on the…more
Everyone writes about the FCPA and the UK Bribery Act. Some are more willing to tackle export compliance. Given the Obama Administration’s reliance on sanctions as a foreign policy tool, companies need to address the…more
Everyone has tips on how to conduct internal investigations. The how-to articles present advice on how to conduct an internal investigation. Unfortunately, the reality is far more complex and risky.
Behind many of the FCPA…more
The test of any compliance program is simple. All you have to do is look to the Chief Compliance Officer and ask these two basic questions:
1. Does the CCO have independent authority and reporting access?
2. Does…more
I have spoken to several in-house counsel meetings about the Laura Stevens criminal case. It is amazing to me how many have not heard about the case or appreciates the implications for in-house counsel and especially global…more
A policy debate requires careful thought and practical evaluations. That is the case with the current flap involving the Chamber of Commerce’s push for reform. The Chamber of Commerce, for all its resources, and brilliant…more
Companies hire lawyers for a reason. Hopefully, they do so for more than one reason. Lawyers provide several important benefits, contrary to all the jokes and ridicule against the profession.
The attorney-client privilege…more
FCPA commentators, like my good friend Howard Sklar, tout the benefits of self-reporting when they discover an FCPA violation. There is no question that if a company self-reports they will get a break. What is not clear, and…more
Lawyers like to complicate issues and then solve them. It is how we stay in business. Lawyers have developed terms which are difficult to define (e.g. reasonable) and then sell themselves as the experts in applying these…more
Federal civil and criminal enforcement against companies is at an unprecedented level. I have repeated this over and over.
In the face of this aggressive enforcement environment, it is time for corporate boards to step up…more
Many of the Fortune 100 companies tout their compliance programs. They are proud of their gold-plated, compliance programs and their record of success. But the world changed recently – especially for the Fortune 100 companies…more
You have to give the Justice Department credit – they are crafty and can be very politically astute. The Justice Department played a very subtle political game with the Morgan Stanley settlement. You have to give them credit…more
The Marx Brothers have always been my favorite. Even today, their movies stand out as the best. One of Groucho’s best lines is particularly apt to FCPA reform.
In A Day at the Races (1937), Groucho passed himself off as…more
Corruption Crime & Compliance welcomes Patrick Kellermann from LeClairRyan who authored this post. Patrick’s biography is located here (see article for link).
For the past decade, money has poured into green businesses and…more
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