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.
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This past week, my second book, “Best Practices Under the FCPA and Bribery Act” was released. Over the past few years I have tried to provide the compliance practitioner with solid information that can be used to implement,...more
In 2012, DOJ and the SEC brought 25 new Foreign Corrupt Practices Act (“FCPA”) enforcement actions, a significant decrease from the number of FCPA enforcement actions brought in 2011 (45) and the prolific 2010 (71). However,...more
“You do not want to be spread too thin”. When I heard that phrase a light bulb went off inside my head. It was uttered to me by Jan Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he meant by the...more
One of the strangest news stories over the past couple of months has been the Manti Te’o story. For those few people who have not heard the story, Te’o was fooled (or not) into believing that he was in an online relationship...more
Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more
Yesterday celebrated an auspicious anniversary as it was the 125th anniversary of the British newspaper, the Financial Times (FT), its first issue having been delivered on February 13, 1888. In England, and across the world,...more
2013 is the 150th anniversary of the London Underground, affectionately known as “The Tube.” It truly is one of the great urban architectural marvels of all-time. The oldest sections of the London Underground completed 150...more
This month, the DOJ's Lanny Breuer provided a direct response to the U.S. Chamber's call for an affirmative FCPA compliance defense. This article outlines the various components of that response....more
I thought about the Astros futility when reading about the Criminal Enforcement Agreement (CEA) entered into by Gibson Guitar Corp (Gibson) for violations of the Lacey Act, which is a 111-year-old law, originally enacted to...more
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