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Training The Foreign Corrupt Practices Act Compliance

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Code of Conduct Training – Now What?

by Michael Volkov on

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

Dave Edwards, the Doomsday Defense and Execution in Compliance

by Thomas Fox on

Baker Hughes Inc. Chief Compliance Officer (CCO), Jay Martin, often says that execution is where the rubber meets the road in compliance. I thought about all of that in the context of some of the pronouncements the Department...more

CCOs Cannot Ignore C-Suite Risks

by Michael Volkov on

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

Make Sure You Address Compliance with Export Controls

by Michael Volkov on

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

Compliance Training, Part I

by Thomas Fox on

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Compliance Lessons from the Olympus Corporate Integrity Agreement – Part II

by Thomas Fox on

Sir George Martin died yesterday. For anyone born after the break up of the Beatles, this name is probably not too familiar. However, even more than Brian Epstein, the band’s first professional manager, Martin truly was the...more

Common FCPA Issues

by Foley & Lardner LLP on

As our previous posts illustrate, violations of the Foreign Corrupt Practices Act (“FCPA”) can carry a hefty cost. Two issues are commonly the impetus for FCPA violations and, practically speaking, pose significant FCPA...more

3 Ways to Improve Compliance Training

by Michael Volkov on

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

What the Government Expects to Find in an Anti-Corruption Compliance Program

by Dentons on

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue

by Thomas Fox on

In this inaugural Mailbag Episode, I field questions from an earlier podcast on the training of third parties under the FCPA. ...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

by Thomas Fox on

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

by Dechert LLP on

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

Making the Case for Compliance Training for Third Parties

by NAVEX Global on

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

by Thomas Fox on

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Five Quick and Easy Ways To Sabotage Your Compliance Training

by Thomas Fox on

Ed. Note-today we have a guest post from noted ethics and compliance expert, as well as steel guitar player, Chris Bauer. Okay, you know that you need to have effective compliance training but do you really know what...more

FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics

by Thomas Fox on

In this episode I interview doctoral candidate Karen Schuder on her research into the teaching of business ethics. ...more

Creation of Yosemite and Putting Compliance at the Center of Strategy

by Thomas Fox on

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

by NAVEX Global on

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

by NAVEX Global on

A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

by Michael Volkov on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Bringing It All Home, the Two Tough Cookies Wrap It Up For You, Part II

by Thomas Fox on

This one is tough, especially in global organizations. In many countries, you simply cannot run a background check, as criminal records are not public. In others, you can run them, but the criminal offense must be related to...more

Monitoring and Auditing Your Anti Corruption Compliance Program

by Michael Volkov on

Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in...more

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