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 -
News & Analysis as of

How to Ensure the Right Tone at Every Level?

Everyone knows the mantra – yes, we need tone at the top, but we also need tone in the middle and tone at the bottom. Every aspect of this statement, however, requires more work than everyone thinks. Tone at the top is...more

What Are Your Company's New Disclosure Obligations in China? – Potential Anti-Corruption Compliance Implications

In 2014, China adopted regulations intended to update and streamline company periodic reporting obligations. The regulations include a new obligation for compulsory interim disclosure of penalties imposed by PRC regulators...more

A Neglected Compliance Task: Program Assessments

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

FCPA Compliance and Ethics Report-Episode 151-Glenn Lammi of the Washington Legal Foundation [Video]

In this episode I visit with Glenn Lammi of the Washington Legal Foundation who discusses the work of the WFL....more

A Journey to the Dark Side of Business Ethics and Steps to Protect Your Organization

On May 11th, 2015 I will lead a session at the GRC Summit 2015 titled “A Journey to the Dark Side of Business Ethics and Steps to Protect Your Organization.” My journey comes not from the fields of audit, law, investigation...more

Lions and Tigers and Bears – Certifications, Checklists and Standards

The compliance profession continues to rise in importance. Companies are paying more attention to corporate culture and devoting resources to enhance existing compliance operations. This approach is reinforced with each week...more

Five Step Process for Transaction and Continuous Controls Monitoring

Most Chief Compliance Officers (CCOs) and compliance practitioners understand the need for transaction monitoring. Whether it be as a part of your overall monitoring of third parties, employees, or to test the overall...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

March Bribery Digest – Beyond FCPA Compliance

Today’s bribery digest is a little bit different than our past versions – rather than focusing specifically on FCPA compliance and enforcements, we’re taking a look at bribery news around the world. We’ve got a story from...more

Beyond the Foreign Corrupt Practices Act (FCPA)

When Ethical Boardroom invited me to write this article, I started thinking about issues that go beyond the ‘bolt-on’ model of anti-bribery compliance. For, as Alison Taylor, director of energy and extractives at BSR...more

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more

Data Privacy Challenges & Considerations for Cross-Border Ethics & Compliance Investigations

What investigators need to know—and do—to adhere to data privacy laws relating during ethics and compliance investigations. Investigations of potential misconduct can be taxing for any organization. But for...more

How to Conduct Internal Investigations Outside the United States

Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

Compliance Benchmarks & Standards: A Round Table Discussion

I recently had the opportunity to read a very interesting and engaging Round-Table Discussion in the 2-2015 Issue of the Journal of Business Compliance (Baltzer Science Publishers. Editor-in-Chief: Anthony Smith-Meyer) titled...more

The Two Ps of Compliance: Promote and Protect

I often complain about compliance messaging. Compliance officers have to be careful to avoid becoming viewed as “nattering nabobs of negativism,” as former Vice President Spiro Agnew famously stated about the liberal media....more

Navigating FCPA Risks in Global Private Equity Ventures

In light of the global nature of the private equity industry, minimizing Foreign Corrupt Practices Act (FCPA) risks is an important consideration for private equity firms and their portfolio companies. ...more

PayPal’s Settlement with OFAC Demonstrates Importance of Effective Sanctions Compliance Programs for Financial Institutions

On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with PayPal, Inc., the money services business, to resolve apparent violations of multiple U.S. economic...more

[Event] Massachusetts Employment Law Summit - May 13, Boston, MA

Employers and their HR departments are faced with a host of new issues and challenges. When you’re not navigating new state, federal, and local laws and making sure systems are in place to comply with them, you’re busy...more

Anti-bribery compliance in the UK - check for 'red flags' on any acquisition

When one company acquires another, it has long been common practice for the purchaser to carry out commercial due diligence upon the target company. However, anti-bribery and corruption (ABC) due diligence is often overlooked...more

Dancing on a Wire: Audit Committee Oversight of a Company’s Compliance Program

There are many interdependent pieces of a compliance program; if one function fails, the effectiveness of a compliance program can be seriously threatened....more

International Anti-Corruption Enforcement Efforts

While the US Foreign Corrupt Practices Act (FCPA) is still the most widely recognized and enforcement anti-bribery and anti-corruption law across the globe, there have been a number of initiatives which will lead directly to...more

[Webinar] Insights from a First-Hand Experience With International Bribery - Tuesday, May 5th at 1:00 pm ET

Most compliance officers and practitioners reside in a headquarters building, far from the front lines of international commerce where the realities of business pressures can collide with ethics and compliance programs. Take...more

Applications like WhatsApp are reshaping government investigations and should be refocusing how compliance departments handle...

White Collar, Regulatory Defense, and Investigations Client Update - In today’s high tech world, the ways to communicate are almost limitless. This presents risks for organizations and challenges for compliance...more

FCPA Compliance and Ethics Report-Episode 149-Patrick Taylor of Oversight Systems on developments in transaction monitoring [Video]

In this episode I visit with Patrick Taylor, CEO of Oversight Systems on some of the newest developments in tools to facilitate transaction monitoring. ...more

Assuring Regulatory Compliance Doesn’t Get Lost in Translation

With the expansion of large multinational corporations into developing countries such as Russia, Brazil, India, Mexico and China, a proliferation of global regulatory enforcement actions, including anti-bribery and...more

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