Compliance into the Weeds - SOX Compliance, PCAOB Inspections and Audits
Compliance into the Weeds-Episode 57-SOX Reform or Not?
Compliance into the Weeds-Episode 51, the PCAOB and Compliance
Compliance into the Weeds-Espiode 47
Everything Compliance-Episode 12
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
Compliance into the Weeds-Episode 30-SOX 404(b)
FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II
2023 was another groundbreaking year for whistleblower litigation and bounty awards. The U.S. Securities and Exchange Commission shattered records by issuing a $279 million award and continued to actively enforce the...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
The Department of Justice’s newly launched compensation and clawback pilot program is certain to bring with it numerous implementation hurdles and jurisdictional challenges, but it also incentivizes companies to have in place...more
Can a new Department of Justice enforcement approach make clawback policies covering criminal activities a best practice? The DOJ is implementing a new policy under which prosecutors will make clawback policies for...more
The Department of Justice and the Securities and Exchange Commission have signaled in recent months that they have reinvigorated their focus on executive compensation claw backs, urging companies to adopt compensation...more
DOJ and the SEC Enforcement Division have launched initiatives targeting executive compensation clawbacks. The SEC is aggressively pursuing SOX 304 compensation clawbacks from Chief Executive Officers and Chief Financial...more
Public companies should prepare for a more strenuous auditing process, and the increased likelihood that the information that they share with their auditors could be compelled by the Securities and Exchange Commission (SEC)...more
Modernizing FinCEN’s Whistleblower Program Under the Anti-Money Laundering Act of 2020 - INTRODUCTION - Reporting on multiple international money-laundering schemes last year brought public focus to the anti-money...more
Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: SEC...more
In Part 3 of this series of Client Alerts, we conclude by offering practical advice for reporting companies about how to assess and respond to certain risks when considering their disclosure obligations....more
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more
ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more
Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more
The Justice Department and the Securities and Exchange Commission have dedicated more time and energy to understanding a company’s internal controls and enforcing basic requirements that companies maintain effective internal...more
California’s USDC–ND ruled that Bio-Rad Laboratories’ former General Counsel may use privileged communications to prove his retaliatory-discharge case prosecuted under Sarbanes–Oxley and Dodd–Frank’s whistleblower...more
Now that the dust has settled on this turbulent campaign season, everyone is in the prediction game, especially when it comes to FCPA enforcement. It is easy to make predictions of significant change. It is easy to take...more
November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more
We are thrilled to bring you the third installment of Stinson Leonard Street's Emerging Trends newsletter. We are proud of the depth and breadth of experience and knowledge across our firm's 13 offices nationwide and are...more
At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot Program, appears to be a “routine”...more
I continue my exploration of recent enforcement matters and issues by turning to the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action, which was announced last week. Mike Volkov has called...more
BK Medical, a subsidiary of the Denmark company, Analogic settled an FCPA enforcement action last week with the Justice Department and the SEC for approximately $14 million. Analogic agreed to pay $3.4 million to the Justice...more
If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more
This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more