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Compliance

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -

ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)

by Michael Volkov on

In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system....more

From the Mummy’s Tomb to the Mummy’s Ghost to Professional Development

by Thomas Fox on

Too often your learning goals suffer because you are too busy or too tired to even think about it. Or because you have no time and have other obligations. Yet there is no job, particularly the compliance profession, in which...more

Day 15 of One Month to More Effective Compliance for Business Ventures- Tying It All Together for Joint Ventures

by Thomas Fox on

As I conclude this section on joint ventures, I want to emphasize again the risk they pose under the FCPA. Mike Volkov has stated, “A joint venture requires the integration of disparate company cultures. It can be successful,...more

The Data Report Episode 18: Privacy Shield

by Bilzin Sumberg on

Module Five: International Law (Part III) In this episode of The Data Report, Litigation attorney Jay Ward discusses compliance with the GDPR requirements. Jay examines "Privacy Shield," the framework that provides a set of...more

SCCE Wrap Up – Final Reflections on CEI 2017

by Thomas Fox on

The 2017 SCCE Compliance and Ethics Institute (CEI) is now in the books. Once again, the organization had record setting attendance with over 1,800 attendees from some 41 different countries. During the event, I had the...more

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

by Michael Volkov on

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

What a CEO Needs to Hear to Invest More in Compliance – Strategy

by NAVEX Global on

Does your organization invest in compliance, or just pay for it? This is not a rhetorical question. There’s a big difference between merely covering the expense of a program and investing in it. Investment decisions are...more

OCIE Publishes Risk Alert on Most Frequent Advertising Rule Compliance Issues Found During Examinations

by Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued a National Exam Program Risk Alert on September 14, 2017 (Risk Alert). The Risk Alert highlights...more

ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)

by Michael Volkov on

In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more

Liz Wiseman-Multiplying the Influence of Compliance

by Thomas Fox on

On the second full day of the SCCE Compliance and Ethics Institute (CEI) Liz Wiseman was one of the keynote speakers. Wiseman is the co-author with Greg McKeown of Multipliers: How the Best Leaders Make Everyone Smarter,...more

Deputy Attorney General Announces Comprehensive Review of DOJ Corporate Enforcement Policies

by Latham & Watkins LLP on

Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more

The Compliance Challenge: Managing Legal & Regulatory Risk

by Ropes & Gray LLP on

Ryan Rohlfsen, a Ropes & Gray government enforcement partner, highlights findings from a new report on legal and regulatory risk management, based on a global survey of 300 in-house professionals. To learn more about the...more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

by Thomas Fox on

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

A Closer Look at ISO 37001 – Something Old or Something New? (Part I of V)

by Michael Volkov on

The release of ISO 37001 has triggered an important discussion among legal and compliance professionals. In a five-part series, I plan to address the value of ISO 37001, provide a substantive analysis, and to evaluate the...more

SCCE Preconference Learning – You Are Not Alone in Compliance

by Thomas Fox on

I am writing this today from the Society of Corporate Compliance and Ethics (SCCE) 2017 Compliance and Ethics Institute (CEI). This is the largest annual gathering of compliance professionals anywhere and it is already off to...more

Day 11 of One Month to More Effective Compliance for Business Ventures-Joint Venture Risks Under the FCPA

by Thomas Fox on

Just as the FCPA enforcement field is covered with actions centering around mergers and acquisitions, there are multiple actions involving joint ventures (JVs). JVs continue to plague many US companies up to this day. In many...more

What progress has been made by France as regards the fight against corruption?

by Bryan Cave on

The Group of States against Corruption of the Council of Europe (GRECO) released a report on 28 September 2017 of its assessment of the measures adopted by France to fight against corruption following the recommendations it...more

The Mummy’s Hand and a Risk-Based Approach at the Board Level

by Thomas Fox on

Today we consider the 1940’s film, The Mummy’s Hand as the second installment in Universal Pictures series featuring this creature. Boris Karloff departed the role and it was taken over for one film by Tom Tyler, who was...more

The Data Report Episode 17: What the GDPR Means for American Companies

by Bilzin Sumberg on

Module Five: International Law (Part II) In this episode of The Data Report, Litigation attorney Jay Ward expands his discussion on the GDPR, examining what it means for American companies and how thoughtful steps can be...more

Breaking Down the 2017 DOJ and OIG Compliance Guides

by McDermott Will & Emery on

Earlier this year, DOJ and OIG independently issued guides focused on evaluating compliance program effectiveness. The guides approach the topic from different perspectives but cover overlapping themes and work well in...more

Lawyers Can Be A Positive Force for Compliance

by Michael Volkov on

Lawyers get a bad rap, and I am not just referring to all the lawyer jokes we have heard numerous times. Lawyers get a bad rap when it comes to compliance. Much of it is not deserved – but candidly, some of it is deserved....more

For the Benefit of Mr. Kite – Fiction in the World of Quality Assurance

by Thomas Fox on

The basics were laid out by Peter Wells and Emiko Terazono in a Financial Times (FT) article entitled “Kobe Steel scandal hits Boeing, Toyota and Nissan”. The Japanese company admitted it had falsified “inspection data on an...more

Day 9 of One Month to More Effective Compliance for Business Ventures - Post-Acquisition Integration Plan

by Thomas Fox on

Your company has just made its largest acquisition ever and your Chief Executive Officer (CEO) says that he wants you to have a compliance post-acquisition integration plan on his desk in one week. Where do you begin? Of...more

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