Internal Investigations Compliance

News & Analysis as of

Incident Management – The New Frontier

Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

New FEHA Regulations: Understanding California’s New Requirements for How Employers Handle Employee Complaints

New California regulations require that employers write discrimination, harassment and anti-retaliation policies which include extensive complaint management and investigation procedures. Snapshot - - What has...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

Is Confession Good for the Corporate Soul?: DOJ announces new mitigation credit for self-disclosure of FCPA violations

On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

Refining the Case Management Process: Case management is easiest when you think of the process as having three stages

Once a report is filed, efficiency is the name of the game. The compliance baton is passed from the reporting channels where a report is received to managing the case. It’s easiest when you take the case and map it out...more

Derailing Internal Reviews, Audits, Assessments and Investigations

Following FCPA enforcement actions provides important insights that can be translated into corporate compliance program best practices. One key element of an effective ethics and compliance program is conducting periodic...more

[Webinar] The Definitive Guide to Case Management - March 2nd, 1:00 pm EST

While the number of incidents reported through your hotline is a good data point, you need more data to fill in gaps in order to truly be proactive about mitigating risk, while gaining insight into your entire compliance...more

Rubik’s Cube and the Intersections of Compliance

It is generally believed that the world’s single best selling toy is the Rubik’s Cube, invented in 1974 by the Hungarian Erno Rubik. Although it was initially believed that Rubik’s Cube was built as a teaching tool to help...more

The Year 2016 in Compliance

Greetings from Venice where my wife and I are spending the next few days so this blog post is my first Travel Edition of 2016. Last week I wrote about my thoughts on some of the significant Foreign Corrupt Practices Act...more

Tribute to Bob Fox-The Fair Process Doctrine in Compliance

Today’s is a personal blog post. My father, Dr. Milden Jean Fox, Jr. “Bob” passed away last week. He was born in 1926 and was part of what we rightfully call the “Greatest Generation”. We call them this for a whole host of...more

Creating an Ombudsman’s Office

If your company is big enough and has the resources to consider establishing an internal ombudsman’s function, consider yourself lucky. When compliance professionals and lawyers use the term “ombudsman,” it is important to...more

Defining Compliance 2.0: Key Compliance Partners (Part 5 of 5)

I always use the “Streetcar Named Desire” line to describe the challenges a  Chief Compliance Officer faces – CCOs depend on the kindness of strangers.  It is a little bit of an exaggeration but bear with me. CCOs are not...more

[Event] 2015 Ethics & Compliance Virtual Conference - Nov. 17th, Virtual

Don't miss the largest ethics & compliance industry event of the year! Brand New Topics & Sessions! * Hear nine engaging sessions—including our Keynote by Governor Thomas J. Ridge—and gain practical takeaways to...more

Focus on China - October 2015

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Whistleblower Risk for Private Companies: Misperceptions About Whistleblower Protections Could Cost Private Companies

Sarbanes Oxley made it clear: publicly traded companies must protect whistleblowers from retaliation, or face large fines and legal actions. Yet a widely misunderstood ruling last year by the Supreme Court opened up...more

Eye of the Storm: Be Prepared for Cross-Border Data Compliance Ahead of the January 1 Deadline

The eye at the center of a hurricane is the calmest part of the storm. Winds subside. Blue skies appear. A sense of relief falls over everyone because the immediate danger seems to have passed. But one of the biggest...more

Foreign Bribery: The Inquiry Briefing Paper on the Senate into Australia's Foreign Bribery Scheme

The Commonwealth Senate Standing Committee on Economics is conducting an inquiry into the scope and effectiveness of existing Australian measures to address foreign bribery. It is due to deliver its report in July 2016....more

Latest Developments in Corruption Enforcement in China

The past quarter has been an active one for Chinese government enforcement activities, and the year ahead promises more of the same. Recent developments include: the strengthening of Chinese bribery laws, increased action...more

All In: Information Readiness in the Wake of VW and the Yates Memo

I’m not much of a gambler, so I steered clear of the tables and slots at SCCE’s Annual Compliance and Ethics Institute in Vegas last week. That said, I really think if I’d have made a dollar for every time I heard the words...more

Five Requirements for Organizational Justice

Ethical companies, by definition, have a robust system for internal organizational justice. A company that suffers from unequal treatment of similarly situated executives, managers, and employees cannot maintain an...more

Five Ways to Ensure Board Support for Compliance

A Chief Compliance Officer has a number of important relationships to maintain in an organization. Aside from the support of senior level executives, the CCO has to build an effective working relationship with the board and...more

D.C. Circuit Once Again Upholds Privilege Over Internal Investigation Documents

In United States ex rel. Barko v. Halliburton Co. et al., a qui tam suit we previously covered, the District of Columbia Circuit Court of Appeals once again ruled that defense contractor KBR Inc.’s internal investigation...more

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