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Deere’s Bribery Schemes — Circumventing Expense Controls (Part II of II)

The Deere case is an important reminder for companies to devote proper attention to ensuring robust integration planning for acquired companies.  DOJ has provided important guidance on acquisition practices and the need to...more

The Deere SEC FCPA Settlement: A Textbook Case of Expense Abuse (Part I of II)

The SEC’s recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic...more

Supply Chain “Audits” and Risk Mitigation

We have seen an explosion in the attention paid to legal, compliance and operational risks companies face in supply chain operations.  Depending on the industry, companies have to address a wide-swath of supply chain risks,...more

The Board’s Perspective: Wrapping Your Arms Around Risks

Diligent conducted numerous board education sessions at which board members spoke about new and significant risks; these included increased stakeholder expectations and the burdensome review of education and documentation...more

The Importance of Compliance Independence

The issue was a professional debate over the reporting relationship between the chief compliance officer (CCO) and the chief legal officer (CLO)/general counsel. After 20 years of debate, CCOs managed to sway the professional...more

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

SEC Outlines “Effective Cooperation” Standard

The Securities and Exchange Commission is catching up to DOJ.  Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Compliance “Curse” — Learning to Compromise Principles

Compliance lessons are life lessons.  Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal.  Compliance professionals live in the shadow of...more

Tracking FCPA Individual Enforcement

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

DOJ’s New Whistleblower Program: Filling in the Gaps and Encouraging Tips (Part II of II)

DOJ is joining the whistleblower reward sweepstakes in a big way.  While the SEC has been grabbing headlines for its whistleblower reward program since 2010, DOJ now wants a piece of the action.  DOJ cited gaps that exist...more

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more

Episode 331- NAVEX State of Risk and Compliance Programs [Audio]

NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine [Audio]

Listen to this conversation between Michael Volkov and Halyna Senyk in which they focus on Ukraine's anti-corruption efforts amidst the backdrop of its ongoing war with Russia. Halyna Senyk, an expert from the CEELI...more

NAVEX’s Report on the State of Compliance: Positive News with Serious Gaps Noted

NAVEX delivers quality studies and important insights on ethics and compliance topics.  In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

District Court Rejects Challenges to ITAR Criminal Charges

On July 9, 2024, District Judge David Hale in Kentucky denied motions to dismiss and motions to suppress filed by four defendants against a criminal case involving ITAR charges for illegal exports of sensitive,...more

SEC Expands Internal Controls Provision to Cover Cybersecurity Incidents and Reaches $2.1 Million Settlement with R.R. Donnelley &...

In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. (“RRD”) for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more

Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility [Audio]

Bryn Sedlacek, Vice President, Product Manager at Aravo, joins us on the podcast to discuss third-party risk management with a focus on holistic risks and unified visibility. In a wide-ranging discussion, Mike Volkov and Bryn...more

Episode 327 -- Another Look at the Importance of Corporate Culture [Audio]

LRN has issued another important report -- in its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable...more

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

Episode 325 -- AI and Emerging Compliance Frameworks [Audio]

A new compliance cottage industry surrounds artificial intelligence. We are at such an early stage of AI development, and companies are still figuring out how they can employ the technology. However, some industries, such as...more

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC...more

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

Episode 324 -- Third-Party Risks and Sanctions Compliance [Audio]

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

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