Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
Webinar: Investigating and Resolving Sexual Assaults on Campus
Information Governance Will Replace Predictive Coding As Biggest Trend in E-Discovery—Judge Peck
One of the most divisive moments in American history occurred on this date in 1868. On this day the US Senate voted against impeaching President Andrew Johnson thereby acquitting him of having committed “high crimes and...more
Brief Explanation of Internal Benchmarks - While senior leaders and board members often express concerns about how a company’s data compares to external benchmarks, it is equally important that companies review their...more
Introduction: High Pressure Regulatory Environment - Now more than ever, there is increased regulatory pressure on organizations – and their Boards of Directors – to create and maintain effective ethics and compliance...more
The second day of Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston packed as much solid information into it as did the first day. One of the sessions dealt with utilizing other corporate functions to...more
The Justice Department and the SEC should be credited with promoting new compliance strategies and best practices. Whatever you may think about the DOJ/SEC FCPA enforcement program, they have pushed businesses to enhance...more
On April 5, 2013 the U.S. Court of Appeals for the 11th Circuit issued its opinion in Landolfi v. Melbourne1, holding that although an employee’s military service motivated the employer’s promotion decisions, his Uniformed...more
In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more
Tomorrow, April 20 is the anniversary of a truly innovative work of literature. On April 20, 1841, Edgar Allen Poe’s story, The Murders in the Rue Morgue, first appeared in Graham’s Lady’s and Gentleman’s Magazine. The tale...more
How can you create or revise your compliance program? One of the first steps you should take is to devise an action plan. A recent article in the March edition of the Compliance Week magazine, entitled “Putting Together an...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
What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more
Try to imagine what DaVinci said to himself when he painted his last brush stroke on the Mona Lisa. Or consider what Tolstoy muttered to himself when he put down his pen after writing the last word of War and Peace....more
I often write about what can happen to companies who run afoul of the Foreign Corrupt Practices Act (FCPA). Usually enforcement actions focus on companies and not individuals. However, as is often pointed out by commentators...more
We often talk about tone at the top. But in many ways it is tone further down the organization which is more important for this is where the rubber hits the road and compliance is done on a day to day basis. I recently saw a...more
Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the...more
Spring training is upon us and I have always enjoyed this time of year because, as one might say, ‘hope springs eternal’ especially for baseball fans. But this year I have no hope for the Astros as they have cut their payroll...more
In This Issue: - Overview - Standards and Procedures - Organizational Leadership and Culture - Reasonable Efforts to Exclude Bad Actors From Managerial Ranks - Training and Education - Monitoring,...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
One often hears or reads about complaints that compliance training is dull, nay even boring. I mean, how many times can you expect someone to be lectured to on the riveting subject of the Foreign Corrupt Practices Act (FCPA)...more
Here are the TOP 10 STEPS public and private employers should consider taking to minimize the risk of whistleblower retaliation claims and build defenses where litigation is unavoidable....more
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