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 -
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Avenues for Reporting Employee Concerns

We all like to make things more complex or difficult than they need to be. Consider that a life lesson that we can share with our children, assuming they are even listening to us these days....more

Winter Begins in Valley Forge and the FCPA Professor Teaches in Miami

Today we celebrate one of the seminal turnarounds in US history for on this day in 1777, George Washington lead his beleaguered troops into winter quarters at Valley Forge, Pennsylvania. At that point in time, things could...more

UK Legal HIghlights 2014 And Beyond

Welcome to our 2014 edition of UK Legal Highlights. This publication is a reminder of some of the most important and significant developments DLA Piper reported in 2014, along with some forthcoming developments to look out...more

NAVEX Global’s Most Popular Ethics & Compliance Matters Articles from 2014

This year, we relaunched our blog with the goal of better serving the ethics and compliance community, providing deeper insights on topics that matter most to E&C professionals, as well as best practices and practical steps...more

Gifts, Meals and Then . . . FCPA Enforcement

Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more

The Barko v. KBR Privilege Battle Continues

A high-profile qui tam suit against Kellogg, Brown & Root and Halliburton continues to generate important case law relating to the scope of attorney-client privilege and work product protection given to internal...more

Scrooge and Corporate Settlement Agreements

Although there seems to be a difference in the precise publication date between the online reference sites This Day in History and Wikipedia, today we celebrate the Charles Dickens’ work A Christmas Carol, which both sites...more

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou...more

Seven Things DOJ Insiders Expect Organizations To Know (and Do) About Antitrust Compliance

For most organizations, the risk of violating antitrust laws is real. But when it comes to the most serious of antitrust violations, such as cartels and significant price fixing schemes, there is often an “it won’t happen...more

Top 10 Topics for Directors in 2015

In this issue: - Strategic Planning Challenges - Cybersecurity - Assess the Impact of Advances in Technology and Big Data - Shareholder Activism - The Return of M&A - Risk...more

Investment Management Director Offers Top 10 Lessons Learned in 2014

In a December 10, 2014 speech, Norm Champ, the Director of the SEC’s Division of Investment Management, offered a glimpse at the top 10 industry lessons learned in 2014. While admitting that his Top Ten list “may not be as...more

Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

What If You Threw A Party and Nobody Came? - Planning Ethically Compliant Events to Maximize Government Official Attendance

At this time of the year many companies and trade associations host holiday parties and invite government officials and staff. Strict rules regulate whether attendance is ethically permissible. More than ever, government...more

The OECD Foreign Bribery Report: ‘Too Big to Debar’

“Your criminal actions raise serious questions as to whether you have the requisite personal integrity and business ethics to be a responsible Government contractor.” That’s me. I was debarred from being a government...more

Hiring and Promotion in Compliance – Wait for Great

The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my...more

Seven Key Actions to Accelerate Your Ethics and Compliance Program

We always hear (and talk about) the rise in the compliance profession. Yes, there is increased demand for CCOs and compliance officers. More lawyers are transitioning into the compliance profession....more

SEC Issues Revisions to Regulation AB Telephone Interpretations

On December 9, the SEC issued Compliance and Disclosure Interpretations (“C&DIs”) that comprise the SEC’s interpretations of the rules adopted under Regulation AB II and the Securities Act and the Exchange Act. The new C&DIs...more

The FCPA Compliance and Ethics Report-Episode 114-Doing Compliance, The Book [Video]

In this episode, I discuss my recently released book, Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program...more

Seamus Heaney and Compliance With a Seat at the Table

I have long been fascinated with the Irish poet Seamus Heaney. I came to know him thought his 1999 translation of Beowulf. While I was aware that he had been awarded the 1995 Nobel Prize for Literature, I did not know his...more

On Compliance Leadership: From Edward VIII to LeBron James

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the...more

How To Mitigate Compliance Risk With Effective Investigations Of Whistleblower Hotline Reports

I recently started watching the first season of the television show True Detective. If you’ve seen the show, you’ll know that Matthew McConaughey’s character, “Rust” or “Rustin”, is known for his master interrogation skills....more

International Anti-Corruption Day

Today is International Anti-Corruption Day. This occasion is a good opportunity to think about whether your organization has sufficient systems, policies and controls in place to ensure ethical and responsible business...more

FinCEN Fines Small Credit Union for BSA Violations

On November 25, FinCEN fined a small Florida-based credit union $300,000 in civil monetary penalties for violating the Bank Secrecy Act (BSA). From 2009 through 2014, FinCEN charged that, among other deficiencies within its...more

Kickbacks and Bribery

Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues....more

Supreme Court Case Brings Pregnancy Discrimination Act back into the Spotlight: Key Legal and Cultural Issues Employers and...

When Congress passed the Pregnancy Discrimination Act of 1978, it sent a message to employers that it wasn’t okay to continue discriminating against women because they were pregnant, could become pregnant or because of...more

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