Suzanne Folsom on Corporate Compliance Issues -
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
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
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
In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more
Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last...more
The FCPA Guidance contains many important compliance reminders which should be incorporated into every anti-corruption compliance program. Perhaps the most important observation included in the FCPA Guidance was the...more
The FCPA Guidance includes some important reminders for compliance practitioners. Most significantly, DOJ and SEC want companies to reinvigorate their risk assessment process. ...more
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