News & Analysis as of

Discipline Foreign Corrupt Practices Act (FCPA)

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - January 24th - 27th, Orlando, FL

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Thomas Fox - Compliance Evangelist

Farewell to The Hawk – Fair and Consistent Application of Discipline

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Thomas Fox - Compliance Evangelist

Day 7 Of One Month To Better Compliance Through HR - Six Principles For Compliance Incentives

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives. She posed it with the following question, “Are there mechanisms to enforce compliance...more

NAVEX

New Guidance from the DOJ on Your Compliance Program

NAVEX on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Thomas Fox - Compliance Evangelist

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Thomas Fox - Compliance Evangelist

Ten Hallmarks of an Effective Compliance Program-Hallmark 6

In this 10-episode podcast series I take a look at all ten hallmarks of an effective compliance program as set out in the FCPA Guidance. In this episode I review Hallmark 6-Incentives and Disciplinary Measures....more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Holland & Knight LLP

Establishing an Effective Compliance Program: An Overview to Protecting Your Organization

Holland & Knight LLP on

In This Issue: - Overview - Standards and Procedures - Organizational Leadership and Culture - Reasonable Efforts to Exclude Bad Actors From Managerial Ranks - Training and Education - Monitoring,...more

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