Auditing and Monitoring in Healthcare
New DOJ Guidance Tightens Corporate Enforcement Strategy
Health Care Continues to Drive False Claims Act Recoveries: Thought Leaders in Health Law Video Series
Accountability: At the Heart of Compliance-Boeing, Part 1-Accountability from Employees
Unfair and Unbalanced-Episode 18
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
The U.S. Department of Justice (DOJ) announced Friday a three-year pilot program related to its continued efforts to hold individuals directly accountable for corporate wrongdoing. The two-pronged program incentivizes...more
In our continuing quest to improve how companies manage risk, it’s inevitable we’d eventually discuss the “Three Lines of Defense,” a risk management model for clarifying roles and responsibilities. It explains the...more
Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more
Over the past few blog posts, I have been exploring a recent article in Harvard Business Review by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”. Pisano says the conventional wisdom is innovative...more
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
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
Why it matters - A federal court judge in Minnesota has rejected the motion of a former chief compliance officer to dismiss the U.S. government's claim that he is liable under the federal Bank Secrecy Act for his...more
A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable....more
Corporate boards have been under siege. If you ask a Board member about the changes in corporate governance, risk and accountability, they roll their eyes and lament that the job of a board member has become more complicated...more