Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
Implications of the SEC Cybersecurity Disclosure Rule
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
Privacy Issues from Third-Party Website Tags
False Claims Act Insights - If Everything Matters, Nothing Does: Parsing Materiality in FCA Disputes
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Social Media Risk
FCPA Compliance Report: Erica Salmon Byrne on Closing The Speak Up Gap
Principled Podcast: S11E7 | Fortifying Ethical Frameworks: Navigating Emerging Risks in the Middle East
Episode 327 -- Another Look at the Importance of Corporate Culture
In Brief: Election Law & Government Ethics Unpacked: National Convention Guidance
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Principled Podcast: S11E6 | Ethics & Compliance Evolution in Singapore: Adapting to Global Risks
Episode 315 - Boeing Pays $51 Million for ITAR Violations
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
The EU Whistleblowing Directive
In this program, we will focus on SEC developments affecting, and practical aspects of preparing for, public companies’ annual meetings and annual reports, including compensation, shareholder proposals and corporate...more
On January 17, the Antitrust Division of the Department of Justice announced that it had obtained another in a recent string of guilty pleas as a result of investigations into government contracting by the Procurement...more
Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more
The week of September 12 was an important one for corporate compliance professionals. We saw two high-ranking officials at the U.S. Justice Department give back-to-back speeches outlining ambitious plans to transform the...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
The Justice Department has resumed FCPA enforcement with a bang. The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a...more
The Biden Administration has a lot on its plate – that is obvious. Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....more
On June 25, 2020, the Department of Justice (DOJ) announced that Jack Abramoff intends to plead guilty to criminal violations of the Lobbying Disclosure Act of 1995 (LDA), in what is the first known criminal prosecution under...more
May 4th is universally recognized (at least in the universe I inhabit) as Star Wars Day. According to Wikipedia, “May 4 is called Star Wars Day because of the popularity of a common pun spoken on this day. Since the phrase...more
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
On April 30, 2019, the United States Department of Justice, Criminal Division (“DOJ”), released an updated version of its guidance on “Evaluation of Corporate Compliance Programs” (“Compliance Program Guidance”). This...more
On April 30, 2019, Assistant Attorney General Brian A. Benczkowski announced the release of an updated version of the Criminal Division's "The Evaluation of Corporate Compliance Programs" during a keynote address at the...more
Part 1 of the Corporate Compliance Guidance addresses the following elements of a well-designed compliance program: risk assessment, policies and procedures, training and communications, confidential reporting structure and...more
We all know the saying – A fish rots from the head. Sometimes a clear and simple statement says it all. The Volkswagen diesel emissions cheating scandal is yet another example of C-Suite, even CEO, misconduct....more
Corporate misconduct occurs in a variety of forms. Starting with the basic truism – companies act through people, and when companies engage in misconduct it requires the coordination and collaboration of multiple actors. The...more
Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more
Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more
It was like a bolt out of the blue – United Airlines’ CEO and two senior executives hastily announced their resignation as a result of their involvement in a bribery scandal with the New York Port Authority....more
When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...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
Governor McDonnell’s attorneys put it this way: The Governor’s acts weren’t “official” because “none were any more remarkable than acts that governors unthinkingly take hundreds of times weekly for countless constituents,...more
Insights on the anti-corruption trends that contributed to the Fédération Internationale de Football Association (FIFA) scandal, and six essential characteristics of organizations whose cultures help prevent bribery and...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more
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