Fraud Compliance

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
News & Analysis as of

New Guidance from the DOJ on Your Compliance Program

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

DOJ Issues New Guidance on Corporate Compliance Programs

The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors....more

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more

DOJ Fraud Section Unveils Blueprint for Assessing Corporate Compliance Programs

In the year and a half that has transpired since the DOJ's Fraud Section retained a compliance consultant to assist prosecutors' evaluation of compliance programs, compliance officers, general counsels and white-collar...more

Recidivism Under the FCPA: Zimmer Biomet

Last week Zimmer Biomet Holdings, Inc. paid a high price for its and its predecessors failure to comply with the terms and conditions of 2012 Deferred Prosecution Agreement (the “2012 DPA”). Biomet, having originally paid $23...more

Corporate Law & Governance Update - January 2017

The following developments from the past month offer guidance on corporate law and governance law as they may be applied to nonprofit health care organizations: HEALTH POLICY INITIATIVES - Perhaps the most...more

Godspeed to John Glenn and Failures at Deloitte

Last week, I paid tribute to Greg Lake. It turned out that the first full week of December was the final week for several important, if not seminal, figures. So this week I will pay homage to those who have left us, today I...more

Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a...more

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more

Conflict of Interest Issues – A Significant Risk

In the risk mitigation business, we often focus on legal risks, such as anti-corruption, sanctions, export controls, antitrust and AML. As compliance programs mature, and the CCOs focus on proactive strategies, one key issue...more

When Your Internal Investigator Fails to “Investigate”

A number of recent FCPA enforcement actions have cited common compliance program failures relating to internal investigations. For example, PTC settled FCPA charges with the DOJ and SEC for $28 million. According to the...more

Compliance Isn’t Going Away (and neither should you) – Part I

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Who is Responsible for a Company’s Mood in the Middle? – the Wells Fargo Fiasco

Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.” Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million,...more

Houston Professional Football Stays the Same; Compliance Evolves

The history of professional football in Houston is certainly star-crossed. After winning the first two American Football League (AFL) championships in 1960 and 1961, the Oilers never made it back to the big game. After the...more

Wells Fargo Week, Part III-the Bank Knew All Along

You know it is going to be a very bad day when, as a company’s Chief Executive Officer (CEO), you receive a letter asking the following, “Specifically, the committee should thoroughly examine this issue, including: How it is...more

CEO of World Trade Center contractor found guilty of fraud by misstating compliance with Port Authority’s minority- and...

Public entities at the Federal, state, and local levels set aside contracting opportunities, provide preferential price treatment, or otherwise grant favorable treatment to contractors (1) owned by veterans, women,...more

From Altamont to Airbus

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...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 II

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell...more

OIG Issues New Exclusion and CIA Guidance

On April 18, 2016, Inspector General Daniel R. Levinson announced the publication of updated guidance on how the Office of Inspector General (OIG) makes decisions about using its permissive exclusion authority and requiring...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

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

Trust as a Fig-Leaf of Poor Compliance and Management

Trust is an important, nurturing presence in the workplace. There is a level of trust inherent in all controls, and NGOs are often dependent on trust, especially in emergency operations, distant field offices, and when...more

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