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
Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...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
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
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
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
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
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
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...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
One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of Justice (DOJ) and Securities...more
Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....more
Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and...more
Say what you will – the SEC is making its mark this year in FCPA enforcement. So far, the SEC has brought nine separate enforcement actions, the latest with Bristol-Myers Squibb. I am sure we will see more before the end of...more
This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as his heritage day. My...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
On this day in 1959, occurred one of the more iconic events of the Cold War, that being the Kitchen Debate between US Vice President Richard Nixon and Soviet leader Nikita Khrushchev. It was called ‘The Kitchen Debate’...more
Ed. Note-today we have a guest post from two noted compliance practitioners from Ukraine, Timur Khasanov-Batirov and Andriy Selepey who discuss the dangers of a paper compliance program. Corruption is the main problem...more
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