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3 Basic Steps to Improving the Effectiveness of Anti-Bribery Training

To say anti-bribery training is important is one huge understatement. It continues to be one of the key elements in any effective or any best practices compliance program. The US Sentencing Guidelines contains clear language:...more

Miners Triumph And Opinion Release 14-01

On this date in 1966, the Texas Western University (now UTEP) Miners won the NCAA Basketball Championship, beating the University of Kentucky Wildcats. Now the first round has not even started by March 19, but it is not the...more

Want to Keep the DOJ Away? Get Clear Anti-Corruption Policies and Good, Interactive Employee Compliance Training

Two of the key components of any best practices compliance regime under any anti-bribery and anti-corruption program are policies and training. Policies tie together a company, its business environment, the risks it faces and...more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

Compliance Defense – The Movie

In honor of The Movie Channel’s annual 28 days of Oscar, the upcoming Academy Awards and inspired by Jay Rosen’s prior career and the FCPA Professor’s hypothetical discussion between a Chief Compliance Officer (CCO) and his...more

Internal Investigations: Doing One Can Be A Compliance Best Practice

The US Navy contract scandal took an interesting twist recently when one of its contractors, Inchcape Shipping Services, which had been suspended from doing business with the Navy for “conduct indicating questionable business...more

The Zen of Compliance Best Practices is Intrinsic and Ethics-Based

No compliance officer worth her salt would argue with this statement: “We strive to maintain an ethics-based organization.” But compliance teams, with all of the internal and external scrutiny, with all the regulations and...more

Anti-Corruption Compliance: Enhanced Elements Become The New Norm

The Department of Justice and the SEC have had a profound effect on corporate compliance programs. That is an understatement....more

Here We Come . . . Walking Down [Wall Street] – More “Aggressive” AML Enforcement On The Horizon

I always say that the government does not enforce the laws in secret – they tell business what they plan to do and then they carry it out. The announcement of an enforcement initiative is always followed by a series of press...more

A New Approach To Compliance: “Informed” Risk And Resource Allocation

The compliance field has had an incredible five years. From backwater offices and responsibilities, CCOs are now taking a seat at senior management tables to provide important risk-based assessments and policies to enhance...more

Individual FCPA Enforcement Actions In 2013

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

The Weatherford FCPA Settlement, Part III

Yesterday, I reviewed the conduct which Weatherford International Limited (Weatherford) engaged in over a period from 2002-2011 in connection with its Foreign Corrupt Practices Act (FCPA) investigation, noted the deficiencies...more

Government’s Efforts To Bolster CCOs

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

Fine Tuning Your Anti Corruption Compliance Program [Video]

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

What's the One Thing Missing From Your Corporate Compliance Program?

What's the one thing missing from most corporate compliance programs? For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more

Avoiding The FCA & FIRREA Trap: Practical Tips For Compliance Professionals

As the government becomes increasingly aggressive in its efforts to fight financial fraud, companies naturally are looking for new ways to avoid becoming the next target. In the last two years, the Department of Justice...more

Why A Compliance Defense Will Not Make A Compliance Program Effective

Ed. Note – this week, I am pleased to join my colleagues David Simon, partner at Foley & Lardner LLP, and William ‘Bill’ C. Athanas, partner at Waller Lansden Dortch & Davis, LLP, in a tripartite debate on the efficacy of the...more

Reactive Compliance: An Oxymoron?

People make bad decisions. Companies make bad decisions. ...more

Internal Investigations In A “Bet The Company” Case

Lawyers like to be dramatic. Litigators love to be dramatic. ...more

Gettysburg Day 2: Dan Sickles, Political Generals And The CCO Position

Day 2 at Gettysburg saw the fighting swing south of the village, along a ridge line that formed a fishhook at its end on an outcropping called the Little Round Top....more

FCPA Enforcement Against Broker-Dealers: A New Headache For CCOs

In 2010, Wall Street shuddered when it was disclosed that the SEC had launched an inquiry into financial institutions, investment banks and private equity firms for potential FCPA violations involving interactions with...more

Improving Your Anti-Corruption Training Program

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

The Danger Of FCPA “Proactive” Investigations

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

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