FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA
IP|Trend: Ensuring an Environment of Compliance
Conducting Corporate Internal Investigations
FCPA Compliance and Ethics Report-Episode 102-interview with Bruce Carton
IP|Trend: Keeping Your Start-Up Compliant
FCPA Compliance and Ethics Report-Episode 101-interview with Chris Bauer
FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics
Thinking Compliance When Protecting Your Ideas Internationally
FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions
FCPA Compliance and Ethics Report-Episode 92-Interview with Matt Kelly
FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
Use of HR in Your FCPA Compliance Program
FCPA Compliance and Ethics Report-Episode 87, what are internal controls, Part II
What Are Internal Controls, Part I
The 10 Essential Steps to Implement an Effective Anti-Corruption Compliance Program
Building An Effective Anti Corruption Compliance Program
Anti-Corruption Compliance Program Audits
How to Monitor, Audit and Improve Your Anti Corruption Compliance Program
FCPA Compliance and Ethics Report-Episode 82, continued fallout from GSK in China
Antitrust Enforcement and Compliance Programs
1. WHAT IS FRAUD?
Fraud is a knowing misrepresentation of the truth or concealment of a material fact to induce another to act to his or her detriment.
2. HOW MUCH TIME ELAPSES BEFORE FRAUD IS DETECTED?...more
We recently released our 2014 Global Ethics Benchmarking Report, an annual report that contains a thorough analysis of the previous five years of whistleblower hotline reporting data, that gives the market insight into...more
US government regulators have become more aggressive in their detection and enforcement of fraud against the government. One of the key tools they are using to combat such fraud is the False Claims Act. Most FCA cases are...more
What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices...more
Companies and Chief Compliance Officers have taken significant actions to emphasize the importance of a company’s code of conduct.
A well-designed code of conduct is a foundation for an effective ethics and compliance...more
In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more
Regulators, in-house lawyers and compliance officers told a serious cautionary tale at the recent Practicing Law Institute Broker-Dealer Regulation and Enforcement seminar. Representatives of the Securities and Exchange...more
An interview with Richard Bistrong.
You must read it.
Find out about bribery from the front line from someone who has been there, seen it, done it and got the jumpsuit.
Originally published on...more
In the FCPA world, we tend to get myopic. We see complex issues and business operations through the prism of anti-corruption risks. Businesses and Chief Compliance Officers, however, have a very different perspective....more
Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find...more
A recent decision in a false claims act case, United States ex rel. Bilotta v. Novartis Pharmaceuticals Corporation (Novartis), underscores the importance of policing employee adherence to corporate policies and industry...more
One of my favorite words in the context of Foreign Corrupt Practices Act (FCPA) enforcement is dis-link. I find it a useful adjective in explaining how certain conduct by a company must be separated from the winning of...more
With the rise of the compliance professional, there is a real need for strong support as they design and implement new and innovative compliance programs....more
On this date in 1864, the Union Army phase of the destruction of Atlanta began. While most Southerners credit Union General William T. Sherman with the burning of Atlanta, it was, in reality, Confederate General John Bell...more
The Antitrust Division is a world unto itself. Ask anyone who works there (including me) or worked there and they will tell you that everyone refers to the Antitrust Division as “The Division,” like it is the only Division in...more
There has been increased scrutiny on corporate compliance and ethics programs throughout the country. And corporations are increasingly moving to shore up those policies. But, how do you create an environment within the...more
We have aggregated below the SFO guidance on Self Reporting (available on its website on a number of pages) and importantly recent comments from the Director about it. If you are considering Self Reporting as an option we...more
In a recent interview, OCEG‘s Scott Mitchell discusses integrating your compliance training with the entirety of your GRC program (such as your policy management system and whistleblower hotline) with The Network’s Jimmy Lin,...more
Watch an in-depth webinar discussion focused on conducting corporate internal investigations, both in the U.S. and abroad.
Bilzin Sumberg attorneys Marty Steinberg and Rafael R. Ribeiro present best practices for...more
Recent press reports covering the sale and export of lightly processed condensate from the Eagle Ford Shale have characterized such transactions as a major test to the four-decade-long ban on crude oil exports, and a sign...more
In the third of three posts on the future enforcement of U.K. financial crimes, we explore how to prevent misconduct before it begins by implementing an effective business conduct programme...
Each of the four trends...more
The U.S. Department of Justice, as part of a new policy focus, expects companies to establish compliance programs or risk probation and external corporate monitors in antitrust matters.
Recently, the U.S. Department of...more
Considering revamping your Code of Conduct. Or maybe you're creating one from scratch? Here's a few things you should take into account.
When an organization is about to implement an anti-corruption compliance program,...more
On November 7, 1940, high winds buffeted the Tacoma Narrows Bridge leading to its collapse. The first failure came at about 11 a.m., when concrete dropped from the road surface. Just minutes later, a 600-foot section of the...more
Creating an ethics and compliance program that reaches and maintains peak effectiveness—and supports a strong corporate culture—takes tremendous effort and an unwavering commitment to continuous improvement. In this post, we...more
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