Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
In the final part of the Compliance Lessons from Venice series, we focus on one of Venice’s earliest tools for addressing misconduct: a reporting system predating modern whistleblower programs. Known as the Lion’s Mouth, this...more
There is nothing like an internal whistleblower report about a Foreign Corrupt Practices Act (FCPA) violation, the finding of such an issue or (even worse) a subpoena from the Department of Justice (DOJ) to trigger the Board...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more
I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more
The 2012 FCPA Guidance states the following on investigations, “Moreover, once an allegation is made, companies should have in place an efficient, reliable, and properly funded process for investigating the allegation and...more
Today I conclude my three-part series on internal investigations with Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, by considering some of the challenges you may well face during an...more
As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more