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
The SEC’s Whistleblower program has been steadily gaining momentum. The increase in whistleblower protections and incentives to report misconduct is a real and serious risk…more
The idea of legal “marketing” has been diluted in the last few years. As businesses become smarter consumers of legal services, in-house counsel and Chief Compliance Officers are much better at deciphering legal mumbo jumbo…more
Companies are always fighting against stovepipes. It is inevitable but offices, divisions and/or functions within a company are always seeking an “advantage,” in competition against other parts of the company…more
Companies struggle to put in place an effective program for conducting internal investigations and meting out discipline. One of the first questions which internal stakeholders struggle with is who is responsible for the…more
Summary: In this era of aggressive FCPA enforcement, companies are adopting anti-corruption compliance programs. The Department of Justice and the SEC have warned companies against adopting "paper compliance programs" without…more
Consider it one of my (many) pet peeves – companies claim they have an “ethical” culture and cite the consistent statements by the CEO of his or her commitment to “ethics and integrity.” That’s it, that’s all, we have an…more
Contrary to what parents always tell their kids, when it comes to the authority of a Chief Compliance Officer, appearance is everything.
This may be another in the long line of profound grasps of the obvious, but if a…more
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