Conducting Healthcare Compliance Investigations
Third Party Ethical Audits
Tying Corporate Compliance & Ethics Week to Your Values
Patty Houser on Supplier Codes of Conduct
Abdul Rahman Al Jaabari on a Virtual Reality Code of Ethics & Business Conduct
Susan Roberts on Creating a Compliance Program Book
Cheryl Curbeam on Creating a Compliance App
Compliance Perspectives: Simplifying the Code of Conduct
Employment Law Now IV-65- The Great Debate Part 2: Employee Lawyer vs. Employer Lawyer
Compliance Perspectives: The Impact of Workplace Loneliness
Compliance Perspectives: Compliance and Technology
Compliance Perspectives: Rolling Out New Compliance Initiatives
Podcast - Risk Mitigation & Management: Bringing a Compliance Program to Life
Day 3 of One Month to 360-Degrees of Communications in Compliance-The D&B Experience
I-17 – Engaging Your Employees in Today’s Workplace, Featuring Rick Turner at Whirlpool Corporation
Operationalizing Compliance Through Your Tone in the Middle
Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture
Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine
FCPA Compliance and Ethics Report-Episode 255-revising your Code of Conduct
On September 9, 2024, the U.S. Securities and Exchange Commission (SEC) announced that it settled charges against seven public companies for alleged violations of Securities Exchange Act Rule 21F-17. According to the SEC,...more
If the term “nth supplier” joined your vocabulary recently, you’re not alone. If you haven’t heard the term until now, don’t worry – you’ll be hearing it frequently soon enough. The “nth” supplier is the mythical last...more
Investment advisers offering funds in more than one country are accustomed to adapting to different regulatory requirements. However, the challenges presented by the global regulation of environmental, social, and governance...more
In the world of compliance and risk management, one size does not fit all. Generic policies and procedures may seem like a convenient solution, but they can lead to compliance risks and potential harm. This is why the...more
On September 5, 2023, the Securities and Exchange Commission (the “SEC”) posted and declared effective a Nasdaq rule proposal modifying requirements related to a waiver of the code of conduct in Listing Rules 5610 and...more
The Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have repeatedly emphasized the importance of aligning compensation plans with compliance goals. According to Tom Fox, aligning the compensation...more
Background Note: In their analysis of the Foreign Corrupt Practices Act (FCPA), Adam Rouse, Vazantha Meyers, and Ashish Prasad emphasize the crucial role of robust compliance programs in minimizing liability associated with...more
The Division of Examinations announced its 2022 Exam Priorities in a release dated March 30, 2022. The 2022 priorities are, as usual, a blend of traditional considerations from past programs mixed with new and at times...more
In 2021, whistleblowers will come into their own in ways previously unseen. While the United States has had whistleblower protections for two decades, Europe and the Asia-Pacific region are setting new standards in...more
Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
In Houston, we have experienced energy companies laying off upwards of 30% of their workforce, both in the US and abroad. Employment separations can be one of the trickiest maneuvers to manage in the spectrum of the...more
What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
Westport Fuel Systems, a Canadian clean fuel technology company, and its former CEO, Nancy Gougarty, agreed to settle FCPA charges with the SEC for $4.1 million and $120k, respectively....more
The Department of Justice raised the stakes in spoofing enforcement actions by including racketeering charges in an indictment filed last week alleging spoofing by three traders over many years. The Commodity Futures Trading...more
The issue of “best interest” continues to be a hot topic in the states and trade groups, though one state has fallen out of the running…at least for now. The State of Massachusetts has two pending initiatives. The first is...more
The SEC will vote today on what it’s calling Regulation Best Interest, “which says brokers can’t put their own paychecks ahead of a customer’s needs”—the more-industry-acceptable revision of an Obama-era fiduciary duty rule...more
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more
Recent events involving the former chief executive officer of Energy XXI serve as a reminder that chapter 11 counsel, committees and committee counsel should take a closer look at the C-suite. This is especially true when a...more
Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more
Much has happened since we last reported on the Department of Labor’s Fiduciary Rule. The compliance deadline was extended 18 months to July 1, 2019. A federal appellate court vacated the Fiduciary Rule in its entirety. The...more
Last month, the Securities and Exchange Commission proposed to established a standard of conduct for broker-dealers when making a recommendation of any securities transaction or investment strategy involving securities to a...more
On April 18, 2018, the SEC proposed a package of rulemakings and interpretations aimed at increasing transparency in the relationships of clients with their broker-dealers and investment adviser and address investor confusion...more
In the six months since Securities and Exchange Commission (SEC) Chairman Jay Clayton requested public comments on standards of conduct for investment advisers and broker-dealers, industry participants, investors and other...more