One of the first thing that many companies will try to put in place is a gifts, entertainment and travel policy when looking at an overall compliance program. I find the reality to be that not only is this one of the more...more
Forgive me for taking the FCPA Paparazzi to task but when they deserve it, they deserve it.
A quick diversion — I often am asked by fellow bar members and commenters if I am referring to them as being a member of the...more
Every year around the holidays the U.S. Office of Government Ethics republishes their holiday poem on gifts and entertainment as a reminder to all of us of what is acceptable and what is not. So as the year draws to a close,...more
Federal prime contractors and subcontractors should consider reviewing and updating compliance procedures and employee training relating to entertainment and other business development gratuities in the wake of the Fifth...more
It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more
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