FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more
U.S. Department of Justice (DOJ) Deputy Attorney General Lisa Monaco presented a new policy at a Securities Industry and Financial Markets Association event that requires chief compliance officers (CCO) to certify that...more
Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more
J&F Investmentos (“J&F”) FCPA settlement presents a number of important lessons learned. While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly...more
The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more
Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more
The Office of Inspector General of Health and Human Services expects board members, board audit/compliance committee members, and senior level leaders of organizations to be experienced in compliance oversight. The Board &...more
The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post. Putting those concerns aside, there are some important lessons learned and observations that...more
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more
The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more
At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more
In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying...more
The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more
While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more
Join professionals in ethics and compliance, human resources, legal, audit and training for the annual 2016 Ethics & Compliance Virtual Conference! Learn strategies to help you build a better governed, more risk-aware, and...more
Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more
The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your...more
Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more
There have been a plethora of new books about the Battle of the Somme. Daniel Todman reviewed several in an article for the Financial Times (FT), entitled “Stories of the Somme”. One of the books reviewed, Breakdown: The...more
At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s...more
You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more
There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more
The SEC is setting its sights on individual prosecutions. Both the Justice Department and the SEC have reiterated the importance of prosecuting individuals. DOJ’s Yates Memorandum promises to deliver an increase in civil and...more