Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Compliance professionals are used to internal struggles for influence and resources. Chief compliance officers have devoted years and years to justifying the need to elevate and empower the compliance function. For years,...more
The full agenda for ACI's 36th International Conference on the Foreign Corrupt Practices Act this December is now available. See why this event stands apart as the annual gathering for the worldwide anti-corruption...more
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• Assistant Attorney General Brian A. Benczkowski's recent Memorandum on "Selection of Monitors in Criminal Division Matters" provides new direction to U.S. Department of Justice (DOJ) prosecutors regarding when to require...more
This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more
A CCO never feels like he or she has caught up on compliance program requirements. As soon as one new best practice is identified, a CCO blinks for a moment and then there is a new best practice for them to consider....more
A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more
OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more
A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more
The Securities and Exchange Commission (the SEC or the Commission) brought over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which...more
Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more
The Foreign Corrupt Practices Act (FCPA) addresses the problem of international corruption in two ways: (1) the anti-bribery provisions prohibit individuals and businesses from bribing foreign government officials in order to...more
The proposed rules would require expanded reporting about separately managed accounts and other aspects of an adviser’s business, allow consolidated registrations for certain private fund advisers that operate a single...more
In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more
Plan for the future because that’s where you are going to spend the rest of your life. – Mark Twain. The SEC enforces its books and records and internal controls provisions, most of which involve non-FCPA violations....more
In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more
I was recently inspired by Tom Fox’s excellent writings on the COSO 2013 framework, and his examination of internal controls issues – see here, here, and here. Today, I begin my own series on internal controls but from a...more
Yesterday we celebrated the hard-nosed playing style of Anthony Mason, who recently passed away. Today we honor a true pioneer in professional baseball, Minnie Minoso, or Mr. White Sox. Minoso was the first black Cuban to...more
In this episode I begin a two-part review of the 2014 FCPA year. In this episode I review some of the significant corporate enforcement actions. ...more
This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more