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Board of Directors Federal Sentencing Guidelines

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Parker Poe Adams & Bernstein LLP

Keys to a Strong Compliance Program in 2019

A new year is always about new possibilities and fresh starts. If you are reading this because you are new to the field, welcome from those of us who are a bit longer in the tooth – we are excited for you and want to help you...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 55, the Covfefe Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more

Parker Poe Adams & Bernstein LLP

Compliance Program Oversight - The Board’s Overlooked Role

It’s long been axiomatic that an effective compliance program cannot exist without a strong ethics and compliance culture, which in turn requires the proper “tone from the top.” Yet, when most companies think “top,” they...more

Jones Day

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

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

Ruder Ware

Compliance Officer and Legal Counsel Relationships

Ruder Ware on

I am often asked my opinion whether a general counsel can also serve in the role of compliance officer. At first blush, it seems the general counsel would be a perfect fit for the role because of general knowledge of...more

NAVEX

Understanding the Benefits of Benchmarking & How to Do It Successfully

NAVEX on

To begin, let’s define “benchmarking.” There is often confusion regarding the difference between benchmarking and assessment. ...the process of benchmarking is a subset of compliance program assessment....more

Thomas Fox - Compliance Evangelist

The Board of Directors’ Compliance Committee

Yesterday, together with Baker Hughes Inc. (BHI) Chief Compliance Officer (CCO) Jay Martin, I wrote about a new and innovative compliance committee BHI has initiated, the GeoMarket Compliance and Ethics Committee. In...more

Thomas Fox - Compliance Evangelist

New DOJ Guidance and FCPA Pilot Program – Part IV: Impact

This week I have been exploring the implications of the Department of Justice (DOJ) announcement last week of a new program Pilot Program around Foreign Corrupt Practices Act (FPCA) enforcement, together with the document,...more

NAVEX

Top Ten Ethics & Compliance Predictions & Recommendations for 2016

NAVEX on

To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more

Thomas Fox - Compliance Evangelist

OIG Compliance Guidance for Health Care Governing Boards

On the front page of the Saturday New York Times (NYT) was an obituary for Edward Thomas, who joined the Houston Police Department (HPD) in 1948 and finally retired in 2011 at the age of 90. As reported in the article,...more

NAVEX

Real Guidance (Finally) On the Compliance Oversight Role of Boards

NAVEX on

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

NAVEX

Board Reporting: Elevating Your E&C Program & Engaging the Board

NAVEX on

In This Presentation: - The Board’s Roles and Compliance Responsibilities - The Board Report & Briefing vs. Training - Important Considerations for your Board Report - Case Study - How Can I Tell if my Board is...more

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