The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more
Leveraging 40,000 anonymous ethics hotline reports and expansive customer interviews, Syntrio’s latest analysis uncovers trends in misconduct, reporting, and more...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
The proper balance in corporate prosecutions remains a tricky issue. On the one hand, many argue that large fines and penalties against corporations are needed to deter criminal conduct, while others contend that...more
Discover how to set and accomplish your ESG goals - Environment, Social, and Governance (ESG) is no longer an isolated function within a company, nor is it an issue only for publicly traded companies. It’s front and...more
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
This week I am exploring the Wells Fargo Department of Justice (DOJ) and Securities and Exchange Commission (SEC) settlement of $3 billion. The case presents multiple lessons for the compliance professional and one very large...more
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more
Spikes in sales in high-risk countries do not translate into sustained growth and without an effective compliance program in place your company may actually lose money....more
When a company is compromised by an ethical lapse—employees might be caught making or taking bribes, management could have failed to comply with regulations, or fraud might have been committed in the course of doing...more
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
Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more
I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more
Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more
New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more
Cyber security, corruption and unethical behavior pose significant risks for business enterprises, according to a new survey by EY titled “Overcoming Compliance Fatigue’. At the same time business organizations may be...more
Public servants with the utmost integrity also need to be aware of what is happening ethically around the state. In today’s climate, every public agency’s image is impacted by the missteps or misconduct of others. Below...more