As we begin the dog days of summer and the long spell between July 4th and Labor Day, the Everything Compliance gang returns to its four focused topics. After the commentary we follow with rants.
Matt Kelly considers Trump’s move to politicize the selection process for administrative law judges and what this might mean for agency enforcement going forward.
Tom Fox explores three FCPA settlements See more +
As we begin the dog days of summer and the long spell between July 4th and Labor Day, the Everything Compliance gang returns to its four focused topics. After the commentary we follow with rants.
Matt Kelly considers Trump’s move to politicize the selection process for administrative law judges and what this might mean for agency enforcement going forward.
Tom Fox explores three FCPA settlements incorporating the new FCPA Corporate Enforcement Policy and anti-"piling on" policy (D&B, Panasonic and Credit Suisse). He considers them in light of some of the following questions: Do these matters increase the incentive for companies to self-disclose? Will these and similar resolutions increase compliance or will it go the other way and cause companies to take compliance less seriously?
Jonathan Armstrong discusses GDPR at six weeks post-go-live. Where are we? What is the difference between public pronouncements by regulators and private actions by EU individuals? Where are we going?
Jay Rosen considers the proactive uses of monitoring in areas outside anti-corruption compliance. Here I am thinking about uses to satisfy antitrust agreements with the FTC/DOJ and hospital conversions. See less -
