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How due diligence plays a role in anti-corruption compliance

With the increasing frequency and expanding scope of enforcement globally, organizations need to devote plenty of attention to anti-corruption due-diligence of third-parties that they engage. The value of due diligence is...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

Increasing Risks of Fraud; Compliance Failures; A Willingness to be Unethical

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

SEC ramping up their defences against misconduct

In a recent interview with the director of the Securities and Exchange Commission’s enforcement division, Andrew Ceresney, he noted that the biggest challenge they face is seckeeping up with the “increased complexity of […]...more

Do You Want Your Lawyer To Be Horatius Or Atticus Finch?

I was profoundly disheartened by these recent remarks by SEC Commissioner Kara M. Stein: Are we treating lawyers differently from other gatekeepers, such as accountants? I think we should carefully review the role...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

Ethics and Compliance WIND - April 2014

Ethics and Compliance WIND is your Weekly Industry News Digest for all things compliance. We bring you the latest industry news, so you spend more time staying up-to-date and less time searching....more

“Credit” For An Effective Ethics And Compliance Program

Sometimes we gloss over complex issues using shorthand phrases. Part of that reflects our continuing ADHD society where 140 characters is the most any person can read and understand at one time....more

Ethics & Compliance: Our Give and Take with the Government

Last year, the U. S. Securities and Exchange Commission (SEC) indicated that it would be looking for additional ways to support the work of Ethics and Compliance Officers. Their stance came in part as a result of the Johns...more

White Collar Watch - January 2014

In This Issue: - SEC’s Dodd-Frank Whistleblower Program Report shows best practices make for an effective compliance and ethics program - In unprecedented move, government seeks to extend the responsible...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

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

FCPA Compliance and Ethics Report-Episode 29-Interview with the FCPA Professor-Part 1 [Video]

In this episode 29 of the FCPA Compliance and Ethics Report, I have Part 1 of a 2 part visit with the FCPA Professor about some things on his mind. In this episode, we discuss SEC Chair Mary Jo White's comments about the need...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

SEC Enforcement Division to CCOs: We Are in This Together!

Stephen Cohen, the SEC’s Associate Director of Enforcement, tied robust compliance programs to enforcement “credits”. In remarks to compliance and ethics professionals at the annual conference of the Society of...more

Giving the CCO Teeth: SEC Sanctions Portfolio Manager for Misleading CCO

The SEC brought its first action for misleading and obstructing the work of a CCO this week, finding that a portfolio manager deliberately altered documents and misled the firm’s CCO in an attempt to hide violations of the...more

The Most Profitable Baseball Team Of All-Time And Commitment To Ethics And Compliance

Sorry to interrupt my three-part series on the greatest ethics and compliance article ever written but I just could not help myself. On Monday, forbes.com, in an article entitled “2013 Houston Astros: Baseball’s Worst Team Is...more

Reactive Compliance: An Oxymoron?

People make bad decisions. Companies make bad decisions. ...more

Gettysburg Day 2: Dan Sickles, Political Generals And The CCO Position

Day 2 at Gettysburg saw the fighting swing south of the village, along a ridge line that formed a fishhook at its end on an outcropping called the Little Round Top....more

The NHL And Compliance: Some Thoughts From Alexandra Wrage On Doing Business Ethically

This past week I chaired the Beacon Events Corruption and Compliance – Asia Congress 2013 conference....more

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