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
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Recently, the Supreme Court delivered several rulings that have caught the attention of compliance professionals. In this blog post, we’ll dissect these rulings and explore their implications for corporate compliance. Matt...more
The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks....more
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation and incentives. However, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
In this episode of the FCPA Compliance Report, I welcome back Mike DeBernardis, a partner at Hughes Hubbard, about some of the key developments in ethics compliance and FCPA from Q1 2022. Key areas we discuss on this podcast...more
Ethics and compliance professionals believe in their mission – if they did not, they would not be in the field. E&C professionals believe in the power of positive thinking, ethical conduct, and in the overall ability of an...more
The Annual Gathering for the FCPA & Anti-Corruption Community! ACI’s 38th International Conference on the FCPA is returning IN-PERSON to Gaylord National Resort & Convention Center, Washington, DC on December 1 – 2, 2021....more
DOJ and the SEC have provided unprecedented compliance guidance and information. DOJ has established itself as the preeminent leader in advancing ethics and compliance programs, best practices and innovations. No agency or...more
The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more
In the age of Coronavirus, it could well be time to assess your internal controls beyond a gap analysis. Consider what COSO says about assessing compliance internal controls. In its Illustrative Guide, COSO laid out its views...more
We are on the final countdown, moving closer to Number 500. On Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...more
Many companies have an investigation protocol in place when a potential compliance or other legal issue arises. However, many Boards of Directors do not have the same rigor when it comes to an investigation, which should be...more
What are the obligations of a Board member regarding the Foreign Corrupt Practices Act (FCPA)? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to...more
Today, we conclude our week of Sherlock Holmes-themed blog posts. We finished the review of The Adventures of Sherlock Holmes and moved on to The Memoirs of Sherlock Holmes. Today we conclude with The Adventure of the Gloria...more
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more
What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
Compliance Convergence. In 2019 there were three significant releases of information by the federal government which directly impacted compliance professionals. Two came from the Department of Justice (DOJ) and one came from...more
The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more
The long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was recently announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more
As the administration goes bonkers on the Kavanaugh nomination and the Rosenstein he’s out/he’s in drama, Tom and Jay consider 100+ wins for the Sox and ‘Stros and take a look at some of the week’s top compliance and ethics...more