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The Art of Compliance Testing and Monitoring

Among all the elements of a corporate compliance program, perhaps the most difficult piece to understand is the testing and monitoring of your controls. Clearly the two are important. The U.S. Justice Department says so in...more

FCPA Enforcement Might Take a Pause – Your Compliance Needs Won’t

Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...more

The Importance of Benchmarking Your Compliance Program

Sometimes questions about corporate compliance programs can be more complicated than they first seem. Such was the case when a compliance officer recently asked me, “Can you point to anything specific that says why compliance...more

Bracing for New AI-Fraud Risks

Compliance officers spend lots of time these days worrying about how their own company’s use of artificial intelligence might draw the ire of regulators, but you have another dimension of AI risk to worry about, too. You need...more

Whistleblower Awards Keep Adding New Compliance Pressures

Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more

The Supreme Court Made Its Rulings; Corporate Compliance Needs March On

At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more

From Healthcare Sector, a Big Push for CCO Autonomy

For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more

The Subtle but Significant Shift at U.S. Justice Department

In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

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