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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 -

Day 14 of One Month to More Effective Internal Controls-What is COSO?

by Thomas Fox on

This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance. Finally, I will end with a...more

EMEA & APAC Reporting Volume to Follow U.S. Whistleblower Trends?

by NAVEX Global on

Never has it been more critical to create an open and constructive organisational culture, where employees feel the ability to raise issues freely without fear of recrimination, and to have those issues listened to and...more

Clarence Darrow, the Scopes Monkey Trial and Leadership

by Thomas Fox on

Today we honor one of the ‘Trials of the Century’ from the 20th century, as on this day in 1925, the Scopes Monkey Trial ended with defense attorney Clarence Darrow giving one of his greatest closing arguments, asking for his...more

Day 12 of One Month to More Effective Internal Controls-Board Oversight as an Internal Control

by Thomas Fox on

Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific references to the obligations of a...more

Tribute to Martin Landau and Strength in the Middle

by Thomas Fox on

A company must have more than simply a good ‘Tone-at-the-Top’; it must move it down through the organization from senior management to middle management and into its lower ranks. This means that one of the tasks of any...more

Part 1 of 2: My Sit-Down Interview With Former EEOC General Counsel David Lopez

by Cozen O'Connor on

Michael Schmidt, Vice Chair of Cozen O’Connor’s Labor & Employment Department, discusses current employment law news, trends, developments and guest analysis. This episode presents the first of two parts of a timely and...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

COMPLIANCE INTO THE WEEDS-EPISODE 46-THE POTTED PLANT EDITION

by Thomas Fox on

In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC...more

Farewell to George Romero, Zombies and District Court Supervision of DPAs

by Thomas Fox on

I take a break from my series on the new standard for revenue recognition to honor George Romero who passed away this weekend. If you have watched any monster/zombie picture over the past 50 years, you have witnessed the...more

Evolutions in Whistleblowing: What Federal Contractors Need to Know

by PilieroMazza PLLC on

Last year produced major changes in the whistleblowing landscape: whistleblower protections for federal contractor employees who disclose waste, fraud, and abuse were made permanent under the National Defense Authorization...more

Important Polling Results from BVD Webinar on Beneficial Ownership

by Michael Volkov on

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

2nd Circuit Weighs in on Certifying Classes Involving Foreign Securities

by Burr & Forman on

In In re Petrobras Securities Litigation, the Second Circuit Court of Appeals recently issued an opinion regarding the standards for certifying a class involving foreign securities. Petrobras is a multinational Brazilian gas...more

The Binge-Watching Goldfish: A How-to for Training Millennials

by NAVEX Global on

An attention span is a fickle friend. A great one to have, but oh so hard to keep. This is especially true when we consider the attention spans of those who are soon to make up 70 percent of our global workforce –...more

New Revenue Recognition Standard – Part V: Allocation and Revenue Recognition

by Thomas Fox on

I continue to explore the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

CCO’s and Delusions About a Company’s Ethical Culture

by Michael Volkov on

It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry....more

Day 9 of One Month to More Effective Internal Controls-Mapping Your Compliance Internal Controls

by Thomas Fox on

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The BHP enforcement continued...more

New Revenue Recognition Standard – Part IV: Determining the Transaction Price

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part III: Performance Obligations

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Compliance Report-International Edition-Carlos Ayers on Tropicalizing Your Compliance Program

by Thomas Fox on

In this episode I visit with Carlos Ayers on steps you can take to make your compliance program more effective to employees in Latin America. This includes such things are localizing your training and presentations,...more

New Revenue Recognition Standard – Part II: Contracts

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Corporate Law & Governance Update - July 2017

by McDermott Will & Emery on

The following developments from the past month offer guidance on corporate law and governance law as they may be applied to nonprofit health care organizations: EMERGING NONPROFIT CONTROVERSY - Health system general counsel...more

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

“Too Important to Jail,” the Yates Memorandum and FCPA Criminal Prosecutions

by Michael Volkov on

The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s...more

New Revenue Recognition Standard – Part I: Introduction

by Thomas Fox on

In May 2014, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606) for public business entities, certain not-for-profit entities, and...more

Day 5 of One Month to More Effective Internal Controls-Assessing for Internal Controls in International Operations

by Thomas Fox on

Today, I want to discuss how to assess for your internal controls regime for international operations. It is incumbent that you need to review as much information so you can to understand the financial and operational...more

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