Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more
On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
The SEC's Division of Examinations recently issued a Risk Alert with observations on investment adviser compliance programs, noting numerous deficiencies and weaknesses it has encountered....more
As recent developments in corporate enforcement indicate, the United States Department of Justice (DOJ) continues to emphasize transparency, cooperation, and the importance of a strong compliance program. Enforcement trends...more
Holland & Knight, the Florida Chamber of Commerce and the Miami-Dade Beacon Council hosted the Second Annual Florida Enforcement Summit on Nov. 20, 2019. The half-day program focused on informing the business community how to...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
The number of prosecutions under the Foreign Corrupt Practices Act (FCPA) remains steady, despite early questions about enforcement under the current administration. Additionally, the new EU General Data Protection Regulation...more
On February 7, 2017, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published a Risk Alert listing the five most frequent compliance topics identified on investment adviser examinations completed within...more
Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more
A continuing focus of SEC enforcement is compliance by entities with their disclosed procedures. The Commission’s latest action in this regard resulted in the payment of $6 million by a Credit Rating Agency that not only...more
On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more
The federal government’s health care fraud enforcement efforts expanded this week with an announcement by the Office of the Inspector General (OIG), of the U.S. Department of Health and Human Services, that it has created a...more
The California Attorney General has kicked off a campaign to ensure that companies are complying with their obligations under the state’s Transparency in Supply Chains Act of 2010. On April 1, 2015, the AG’s office sent...more
In this episode I visit with Mike Volkov on his recent series on internal controls under the FCPA and his belief that the DOJ may be moving towards criminal enforcement of the internal controls provisions....more
Companies in the automotive industry would be wise to pay attention to Foreign Corrupt Practices Act (the “FCPA”) compliance. What has in the past been a risk management issue principally for massive multi-national...more
The Department of Justice (DOJ) still faces criticism over its Foreign Corrupt Practices Act (FCPA) enforcement strategy. Some decry that it is too aggressive, that the DOJ has moved into waters Congress never intended the...more
For years, we have all heard about the coming wave of FCPA enforcement against financial institutions, investment banks, private equity firms and others who interact with sovereign wealth funds overseas....more
I have intentionally avoided a Top Five or Top Ten prediction list for Foreign Corrupt Practices Act (FCPA) enforcement going forward from 2014 into 2015. However there is one area of FCPA enforcement, which I think underwent...more
U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more
This week I am focusing on the persistent problem of healthcare fraud. For healthcare providers, the challenge of compliance and avoiding enforcement risks is particularly difficult. ...more
On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more
This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more
From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more
The U.S. Department of Justice, as part of a new policy focus, expects companies to establish compliance programs or risk probation and external corporate monitors in antitrust matters. Recently, the U.S. Department of...more