Episode 335 -- The New DOJ Whistleblower Program
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The Justice Insiders Podcast: DOJ’s Cacophony of Whistles
Understanding the Whistleblower Pilot Program in the Southern District of New York
What's Going on with FCPA?
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Encouraging and Managing Employee Self-Reporting
Compliant Business Communications Through Messaging Apps
Corruption, Crime, and Compliance - DOJ’s Compliance Frontier: Incentives and Disincentives
Internal Investigations for Nonprofits: A Means of Identifying and Addressing Misconduct Before the Regulators Come Calling
FCPA Compliance Report - Matt Galvin and Dan Kahn, Part 2 - Reflections on the Monaco Speech
Digging Deeper Episode 10: Misguided or Misconduct? Understanding Bad Behavior in the Corporate World
Compliance Perspectives: The German Corporate Sanctions Act
KT Sound Bytes Episode 1 | The Effects of the Supreme Court Decision in Liu v. SEC
Fraud and Abuse Enforcement Priorities in the Wake of COVID-19 - Diagnosing Health Care Podcast
Compliance Perspectives: The Compliance Law Track at the 2020 Virtual Compliance and Ethics Institute
Compliance Perspectives: The Right Kind of Wrong
Compliance Perspectives: Compliance Lessons from Theranos
Days to a More Effective Compliance Program-Day 22 | Assessing compliance internal controls
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more
To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
Dada la relevancia que actualmente está obteniendo la prevención de los riesgos y el cumplimiento normativo en el desarrollo de los negocios, la Delegatura de Asuntos Contables y Económicos de la Superintendencia de...more
U.S. Deputy Attorney General Lisa Monaco recently announced the Department of Justice (DOJ) is launching a new whistleblower monetary rewards program later this year and she expects it to drive investment in internal...more
Hong Kong regulators recently brought criminal enforcement actions against virtual asset trading platform JPEX and individuals associated with the platform. This case has become the first opportunity for local authorities to...more
The Criminal Division of the United States Department of Justice (DOJ) encourages companies to cooperate with the government whenever criminal conduct is discovered. A recent case demonstrates how voluntary self-disclosure...more
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Suppose you are a member of an audit committee and learn about a whistleblower complaint alleging wrongdoing at the company. Maybe it’s just an aggrieved former employee, and it has no merit. Maybe you should direct the...more
Fifth Circuit Ruling Against Blue Bell’s Corporate Directors and Officers May Limit Availability of Insurance Coverage in Shareholder Derivative Actions - In a recent ruling, the United States Court of Appeals for the...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone. To the contrary, as the business adapts through growth, innovation or in response to outside market and...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
Ethikos Volume 36, Number 4. October 2022 - Organizational culture seems to be discussed daily, yet few can define it. For our purpose, we can use a simple definition: the way we do things around here. Edgar Schein’s...more
Chief compliance officers have a lot of issues to balance on their plate. Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more
NAVEX recently released its annual Hotline and Incident Management Report. Given NAVEX’s strong position in the hotline service market, NAVEX has access to a large volume of reporting data. As a result, its annual report is...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
Nonprofit entities can be just as prone to misconduct (theft, embezzlement, accounting snafus, executives’ HR violations) as corporations. While there is no foolproof formula to avoid internal crises entirely, knowing...more
Corporations depend on strategic objectives and performance metrics. Senior executives declare the objectives and the metrics they’ll use to measure employees’ progress toward those goals, and employees get to work achieving...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
Everyone is now on the culture bandwagon. For those of us pushing the issue over the last decade, welcome aboard to everyone. But once you join, the work is only beginning. ...more
A corporate scandal does not occur overnight. (Thank you Bob Dylan). A CEO does not begin the day telling him or herself that today is the day to begin the Ponzi scheme or complex fraud. It is hard to imagine but corporate...more
By October, companies in the European Union employing at least 50 employees will be required to operate an internal reporting system for reporting misconduct that may indicate compliance violations. Furthermore, all companies...more