Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
How important is due diligence on those with whom you are doing business? Why does it matter if a company is owned or controlled by a foreign government or a political party member of a foreign government? ...more
This week, on the FCPA Compliance Report, I am running a five-part podcast series on the current state of investigative due diligence. ...more
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more
Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. ...more
This week, I am running a five-past podcast series on the assessment of ethics and compliance in the mergers and acquisition (M&A) context. The podcast series was sponsored by Affiliated Monitors, Inc., (AMI)....more
This week I am running a five-part podcast series on assessing ethics and compliance in the mergers and acquisition (M&A) context on the FCPA Compliance Report. ...more
Deputy Assistant Attorney General Matthew Miner, head of the DOJ’s Fraud Section, recently discussed the DOJ’s efforts to address corruption discovered during mergers and acquisitions....more
In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more
The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more
There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more
Bobby Keys died last week. What you probably did not know was that Keys was a Texan so we get to claim him. He was the saxophonist for the Rolling Stones and a number of other serious rockers. ...more
In a recent Opinion Procedure Release (OPR), Number 14-02, the U.S. Department of Justice expressly limited successor liability for a US company purchasing a non-US company that had paid bribes in the past. In so doing, DOJ...more
The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...more
Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more