Suzanne Folsom on Corporate Compliance Issues -
With companies soon facing new enterprise risk and corporate governance requirements, this alert discusses whether companies are prepared for state implementation and outlines new NAIC actions relating to conducting an...more
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more
Program and culture assessments - Assessments have long been recognized as having a critical impact on the effectiveness of ethics and compliance efforts. Best practice programs have often employed assessments – formal...more
Today we celebrate that noted British comedian who made his fame in America – Bob Hope. ...more
Can you synthesize and reconcile the world’s leading laws, regulations and commentaries on the best practices an anti-bribery and anti-corruption compliance program. ...more
The bottom-line: If you do not conduct a risk assessment, then you should start praying. The FCPA Guidance made it clear – conduct a risk assessment and tailor your compliance program to the risk assessment....more
I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do compliance. As the...more
Like every compliance project, when you start the process, it is important to conduct a careful assessment of risks and your company’s compliance program. With the growing risk of criminal, civil and regulatory enforcement...more
Virtually every authoritative source of guidance on effective anti-corruption compliance emphasizes the importance of conducting a company-wide “risk assessment.” For example, U.S. authorities have stressed with regard to the...more
I used to say – if your business operates in China, you are likely violating the FCPA in one way or another. Permit me to revise my admonition: if your business operates in India, you are likely violating the FCPA in one...more
I attended the Dow Jones Global Compliance Symposium over the past couple of days. It was a great conference and kudos to the entire Dow Jones team for putting on a truly memorable event. Day 2 had some interesting speakers...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
“You do not want to be spread too thin”. When I heard that phrase a light bulb went off inside my head. It was uttered to me by Jan Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he meant by the...more
Supply chain compliance is on the government’s enforcement radar like never before. If the recent Executive Order on Trafficking in Government Contracts and final SEC Conflict Minerals Rules were not notice enough, the...more
No matter how strong a company’s compliance program, there is always a risk. No matter how many times employees are trained, complete certifications and are reminded of their FCPA compliance obligations, there is always a...more
What is the gold standard for scientific minds? You might not do better than Albert Einstein who was born on this date in 1879. While most lay persons remember Einstein for his theory on special relativity, and his attendant...more
If you look back five years and ask – how much has changed in the compliance world in the last five years? – the answer is remarkable. I can easily make the argument that the biggest change in corporate governance over the...more
I recently read “War Room: The Legacy of Bill Belichick and the Art of Building the Perfect Team” by Michael Holley which is about Bill Belichick, the rise of the New England Patriots and the sophisticated player evaluation...more
The Justice Department’s message is getting through. The two-fisted strategy of aggressive enforcement and public cajoling on the importance of compliance is being heard by the business community. The Justice Department and...more
One of the concepts articulated in the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) Guidance was that every company should assess its own risks for bribery and...more
I recently sat down with Suzanne Folsom, the former Vice President, Chief Regulatory and Compliance Officer, and Deputy General Counsel at AIG, to discuss how companies can best navigate an increasingly tough regulatory...more
In this presentation: - Recent Examples of Nonprofit Embezzlement - Why Does Employee Fraud Occur? - Why Are Nonprofits Frequently the Victims of Embezzlement? - External Audits - Fraud Risk...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has published its list and discussion of examination priorities for the investment management industry in 2013, which includes both market-wide initiatives...more
In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more
Ed. Note-today we continue with our series on thought leaders and practitioners in the compliance arena. Today, we have an interview with Scott Moritz, who is a Managing Director, Protiviti (www.protiviti.com)...more
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