Internal Investigations Compliance

News & Analysis as of

One Anti-Corruption Compliance Panel: Multiple Perspectives

On July 23rd, 2015 at the Hotel Kitano in New York City, The Network (www.tnwinc.com) hosted an Anti-Corruption Compliance Panel discussion titled “Why Anti-Bribery Programs Fail and How Compliance Must Evolve.” Cindy Curtin...more

How to Respond to a CFPB Civil Investigative Demand

The Consumer Financial Protection Bureau (“CFPB”) was created to enforce the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) and various consumer finance laws (e.g., Equal Credit Opportunity...more

Leveraging a Global Compliance Network

Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true....more

E-Discovery: If you can’t take the data to the tools, take the tools to the data

Today we welcome Jo Sherman, CEO, EDT Inc. to share some of her thoughts on the challenge of international investigations and data collection/analysis. Given the challenges of discovery and data collection across borders in...more

A Review of Recent Whistleblower Developments

SEC Awards Another Whistleblowing Compliance Officer - On April 22, 2015, the Securities and Exchange Commission (SEC) announced an award between $1.4 and $1.6 million to a compliance officer who provided information...more

Under scrutiny: Internal investigations - Internal investigations are becoming increasingly commonplace, but how do you cope when...

There has been a sustained rise in investigations and enforcement actions taken by regulatory authorities in the wake of the financial crisis. As companies try to get back on track, internal investigations have also become...more

Our Picks for the Top 10 Ethics and Compliance Articles You Don’t Want to Miss This Month

With so many articles available every month, it’s possible that a few got buried in either your inbox or the bowels of the blogosphere. Here are ten articles you don’t want to miss...more

Corporate Investigations & White Collar Defense - May 2015

It’s an Absolute Privilege to Meet You! Texas Supreme Court Rules That Internal Investigation Report Provided by Shell Oil to DOJ Enjoys “Absolute Privilege” - Why it matters: On May 15, 2015, the Texas Supreme Court...more

Senn on 10 Best Practices in a Cross-Border Investigation – Part I

Today we celebrate a closure for it was on this day in 1935 that probably the best-known baseball player in the history of the game, George Herman ‘Babe’ Ruth, retired. While many of his records were broken with the march of...more

Preventing the Worst: Stopping Obvious and Bold FCPA Violations by Executives

Last year, a number of corruption cases, both individual prosecutions and suits against companies, revolved around the behavior of senior executives. While third parties can often be the vehicle companies use to funnel bribe...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

The Recent SEC Attack on Confidentiality Agreements: What Employers Need To Know and Do Now

Introduction - • Employers typically impose confidentiality restrictions to protect trade secrets and confidential information, including when conducting internal investigations and in employee separation...more

Senn Interview, Part III – Post Incident Remediation

I conclude my three-part series based upon my podcast interview of noted white-collar defense lawyer and Foreign Corrupt Practices Act (FCPA) practitioner Mara Senn, a partner at Arnold & Porter LLP. In Part I, I considered...more

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose [Video]

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Reinventing Compliance Program Metrics

One of many pet peeves I have in the compliance space is the lack of creativity in compliance program measurement. Chief Compliance Officers have to take a fresh approach to this issue....more

Navex Global's 2015 Ethics and Compliance Hotline Benchmark Report

Experienced ethics officers will tell you that one of the most effective ethics and compliance program measurement tools they have is the data from their internal reporting systems. But how do you put that information into...more

Not Necessary to “Boil the Ocean” in FCPA Internal Investigations

Assistant Attorney General Leslie R. Caldwell recently gave her views on the proper scope of internal investigations regarding FCPA matters. In her views she noted...more

Internal Investigations and Cooperation Credit in FCPA Investigations

Cooperation credit and conducting internal investigations were key themes in recent remarks by Assistant Attorney General Leslie Caldwell at New York University Law School’s Program on Corporate Compliance and Enforcement...more

Data Privacy Challenges & Considerations for Cross-Border Ethics & Compliance Investigations

What investigators need to know—and do—to adhere to data privacy laws relating during ethics and compliance investigations. Investigations of potential misconduct can be taxing for any organization. But for...more

How to Conduct Internal Investigations Outside the United States

Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

Do Your Confidentiality and Employment Agreements Violate SEC Whistleblower Protection Rules?

As the SEC takes aim at whistleblower “pretaliation” (attempts to muzzle whistleblowers via confidentiality and other employment agreements—overt or otherwise) ethics and compliance officers need to take practical steps to...more

SEC Warns Companies and Lawyers not to Mute Whistleblowers through Confidentiality Agreements

Companies should take note that the Securities and Exchange Commission has charged KBR Inc., a technology and engineering firm based in Houston, with violating Rule 21F-17 under the Securities Exchange Act of 1934, as...more

Never Let Them See You Coming—Keys to Setting Up Witnesses Interviews In An Internal Investigation

“So you are the great lawyer I’ve been told about!  But, you are so young!  I was expecting an old lawyer.” With those words, the silver-haired senior-level executive of the customs broker I was investigating for bribery let...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Uncovering the “Why” in FCPA Compliance Issues [Video]

Jan. 8, 2014 (Mimesis Law) -- With the consequences of FCPA noncompliance ranging from “huge” to “catastrophic,” compliance should be top-of-mind for U.S. companies doing business with third-party intermediaries and...more

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