The Foreign Corrupt Practices Act Chief Compliance Officers

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.
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The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

CCO Independence, Authority and Resources as Indicia of an Effective Compliance Program

At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Up Close and Personal: Individual CCO Liability – Part II

Yesterday I began an exploration of the potential individual liability of a Chief Compliance Officer (CCO) based upon the Financial Industry Regulatory Authority (FINRA) enforcement action against Raymond James Inc. and its...more

Up Close and Personal: Individual CCO Liability – Part I

A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV...more

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

Joe Howell on the PCAOB, Audits and Compliance – Part I

I recently had the chance to visit with Joe Howell, the Executive Vice President (EVP) of Workiva LLC. Howell has been the Chief Financial Officer (CFO) of a number of public companies, mostly in the technology space, and...more

[Webinar] FCPA Spotlight: Best Practices for Controls and Records - May 20th, 1:00pm EDT

In this era of increased attention to corruption, the U.S. Justice Department and Securities and Exchange Commission are increasingly using the FCPA's books and records and internal controls provisions to prosecute improper...more

GHBER Tribute to Jay Martin

This Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

Tribute to Dr. Jannetta and Improvisation in Compliance

It is rare you are able to write about someone who directly changed the quality of your life. Rarer yet that you did not know about him, only what he created, until you read his obituary. That happened to me recently when I...more

Who Can Fire a CCO?

There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more

Shakespeare Week – Part III: Much Ado About Nothing and Incorporation of Social Media into Your Compliance Program

How does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on...more

Shakespeare Week – Part I: Henry IV, Part II – Lawyers and Compliance

What is the most famous line in Shakespeare about lawyers? That is an easy one because lawyer-haters across the world (and lawyer-lovers as well) know it – First thing we do is kill all the lawyers. It comes from Henry IV,...more

Big Data in a Best Practices Compliance Program, Part III-Visualization

Today I continue my exploration of big data in a best practices Foreign Corrupt Practices Act (FCPA) compliance program. Yesterday, I considered how you might use big data in a best practices compliance program. Today I want...more

Big Data in a Best Practices Compliance Program, Part II

Today I continue my exploration of big data in a best practices Foreign Corrupt Practices Act (FCPA) compliance program. Yesterday, I considered what big data is and some ways to think about it. Today I want to move into some...more

Big Data in a Best Practices Compliance Program, Part I

I have founded several podcasts, one of which is Compliance into the Weeds, where Matt Kelly joins me each week take a deep dive into the weeds of a compliance related topic. As many of you know, Kelly is the former...more

New DOJ Guidance and FCPA Pilot Program – Part IV: Impact

This week I have been exploring the implications of the Department of Justice (DOJ) announcement last week of a new program Pilot Program around Foreign Corrupt Practices Act (FPCA) enforcement, together with the document,...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

[Webinar] Practical Guidance for U.S. Companies Expanding into Europe Through Commercial Arrangements - April 6th, 9am PST, 11am...

Please join us for a discussion focused on providing practical guidance to U.S. multi-national companies looking to grow their businesses in the European market. Panelists will consider various types of commercial...more

Prog Rock Week – Part III: Watcher of the Skies and Staying Sane as the CCO

As noted by Dan Epstein, in the Rolling Stone article “50 Greatest Prog Rock Albums of All Time”, the Genesis album Foxtrot was arguably the band’s first great album. The album “took the eccentric worldview and symphonic...more

Prog Rock Week – Part II: Karn Evil 9 and Kaizen for Compliance

Yesterday, I began Prog Rock Week with a tribute to Keith Emerson. So sit back my friends and enjoy the show that never ends, as I explore my favorite prog rock albums and cuts. Today, I will further honor Emerson and his...more

DOJ Fraud Section Chief and Compliance Counsel shed light on compliance program evaluations: the four areas of inquiry

There has been quite a buzz since the Department of Justice announced last year that it had appointed a compliance counselor to aid prosecutors’ evaluation of compliance programs and would focus on individual culpability for...more

The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance

The U.S. Department of Justice announced last week that Olympus Corporation of the Americas (OCA) agreed to pay $646 million to resolve three cases relating to its longstanding practice to bribe doctors and hospitals in the...more

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