31 Days to a More Effective Compliance Program - Charitable Donation Enforcement Actions
Transaction Monitoring Under the FCPA
Seventh Circuit Jumps Ahead of SCOTUS, Rules Pharmaceutical Sales Reps Exempt from Overtime—Jackson Lewis’ Noel Tripp
When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and violates the FCPA. This was a feature of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the SEC in...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives initially rejected the...more
One of my weekend reading pleasures is the Saturday section in the Financial Times (FT) entitled “Lunch with the FT”. ...more
FCPA practitioners tend to repeat themselves. Some of the points we make need to be repeated, and some do not. Businesses are not able to react as quickly as they should in response to potential risks and possible...more
As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more
This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more
In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more