News & Analysis as of

Advice on Medical Marijuana for Lawyers in Pennsylvania

The Controlled Substances Act, 21 U.S.C. Section 811 et. seq. (CSA), enacted in 1970, provides that marijuana is a "Schedule I" drug because, in the words of the CSA, it has a "high potential for abuse," "no currently...more

“Is the Current Compliance Model Working?”

An interview with Richard Bistrong. You must read it. Find out about bribery from the front line from someone who has been there, seen it, done it and got the jumpsuit. Originally published on...more

FCPA Compliance and Ethics Report-Episode 104-interview with Russ Berland [Video]

In this episode, I visit with Russ Berland, who was outside counsel heading up the FCPA investigation for Layne Christensen. I discuss with Russ the fabulous he was able to achieve, a Declination to Prosecute from the DOJ and...more

DOJ’s Marshall Miller: You’re All FCPA Lawyers Now

Marshall Miller, the Justice Department’s principal Deputy Assistant Attorney General for the Criminal Division, has been heating up the compliance conference circuit in recent weeks. On September 17th, it was the Global...more

Tommy Lewis, Dicky Maegle and the DOJ Call for Individual Prosecutions

Tommy Lewis died this week. For those of you uninitiated in college football, Lewis was an Alabama football player who jumped up off the Alabama bench to tackle Rice University halfback Dicky Maegle, who was scampering...more

Government's Message to Corporate America — "We Want Your Whistleblowers!"

On September 22, 2014, the Securities and Exchange Commission's (SEC) Office of the Whistleblower announced that it had issued a $30 million bounty payment to a foreign whistleblower. This award is more than double the...more

How To Strengthen Your Ethics And Compliance Policy Management

People say that hindsight is 20/20. I’d say from my experiences its true. If only we could have 20/20 vision before an incident occurs, think of all the heartaches and headaches we could avoid. It would be especially helpful...more

TNG Premiers and Internal Controls for Gifts in a Best Practices Compliance Program

This week, 27 years ago, Star Trek – The Next Generation (TNG) made its television debut. Rarely has there a follow up to a beloved original series (Star Trek – The Original Series (TOS)) that is equally treasured by fans. ...more

The Houston Astros and a Compliance Defense in the FCPA

The Astros act like a corporation and like almost all corporations they look to pay the absolute cheapest that they can to get something. Those who advocate that there be a compliance defense added to the FCPA miss this...more

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

Compliance in the C-Suite

The ongoing debate whether certain executives are “too big to jail” misses the most important trend in corporate governance – namely, that criminal conduct is rising in the C-Suite. Viewed from a broad perspective, since...more

FCPA Compliance and Ethics Report-Episode 62-Self Disclosure Issues Under the FCPA, a conversation with Bill Athanas and David... [Video]

In this episode I visit with Bill Athanas and David Simon on what issues a company should consider when evaluating whether it should self-disclose to the DOJ/SEC about potential FCPA violations...more

Implementing Compliance Incentives In Your Company

Several readers have asked why I have not written anything about the Houston Astros this year. The answer is two-fold. The first is that I really do not care. However, the more I thought about it, the real reason is that they...more

Commitment To Compliance: The Compliance Committee

Sunday was the 69th anniversary the most iconic photo of World War II, at least from the American perspective. Of course it was the raising of the American flag at Mt. Suribachi on Iwo Jima. To say that one photo cannot...more

The Zen of Compliance Best Practices is Intrinsic and Ethics-Based

No compliance officer worth her salt would argue with this statement: “We strive to maintain an ethics-based organization.” But compliance teams, with all of the internal and external scrutiny, with all the regulations and...more

Each Case Is Unique – Drawing Lessons From Opinion Release 13-01

“Each case turns on its own facts.” How many times have you heard a representative of the Department of Justice (DOJ) or Securities and Exchange Commission (SEC) make that statement at a conference or other public event?...more

Mandatory Training for Third Parties – Effective or Protective?

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

2014 Trends: #1 Third party risk – still the ethics and compliance ‘Achilles heel’

As we embark on 2014, we’ve pulled together key ethics and compliance industry trends with an eye towards planning for the year ahead. To help, we’ve asked industry experts, our colleagues at NAVEX Global and ethics...more

A New Approach To Compliance: “Informed” Risk And Resource Allocation

The compliance field has had an incredible five years. From backwater offices and responsibilities, CCOs are now taking a seat at senior management tables to provide important risk-based assessments and policies to enhance...more

Keep Your Hand On The Control

I am continually amazed at the seemingly disparate current events which provide tangible lessons for the compliance practitioner. In an article in the New York Times (NYT), entitled “Hearings on San Francisco Crash Set to...more

How Straight From The Lion’s Mouth Informs Your Hotline

The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could...more

Plato, Aristotle And Codes Of Conduct

It was once observed that all western philosophy is but a mere footnote to the works of Plato. However others believe that his student Aristotle merits equal standing....more

Are DPAs Morally Suspect?

You know it is going to be a bad day when you are excoriated in public by a sitting federal district judge. It is even worse when the comments of that federal judge make it into one of the most prominent international...more

What's the One Thing Missing From Your Corporate Compliance Program?

What's the one thing missing from most corporate compliance programs? For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more

Paradise By The Dashboard Light And Compliance Tune-Ups

Meatloaf’s standard Paradise by the Dashboard Light, is the lead in for today’s blog post (the ‘automotive’ focus of the song and not the ‘paradise’ focus for the less prurient among you.) I still think that one of the most...more

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