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Human Resources Professionals Foreign Corrupt Practices Act (FCPA)

Fisher Phillips

Workplace Law Forecast 2024 - Your workplace law recap for 2023 and predictions for 2024 to help you prepare for the coming year.

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When I reflect on the relationship that our firm has with our clients, I’m most proud of the fact that you can always count on us. That often means defending complex litigation, steering you through regulatory threats,...more

Lowenstein Sandler LLP

Trade Matters -Lowenstein Sandler's Global Trade & National Security Newsletter - June 2023

Lowenstein Sandler LLP on

Crypto Asset Company Settles Sanctions Violations for $7.5 million- On May 1, the U.S. Department of Foreign Assets Control (OFAC) announced a $7.5 million settlement with crypto asset company Poloniex LLC for 65,942 apparent...more

Morrison & Foerster LLP

Crossing the Line: Hospitality, Gifts, and Unfair Dismissal

Morrison & Foerster LLP on

Mr D Thompson v Informatica Software Ltd- In a recent appeal at the EAT an individual (the “appellant”), who had been a senior employee of the employer (ISL), was found to have been fairly dismissed for gross misconduct...more

Thomas Fox - Compliance Evangelist

The Role of HR in Creating an Ethical Culture

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

Thomas Fox - Compliance Evangelist

A Fourth World Cup and Compliance

Today we honor the US Women’s Soccer team who won their fourth World Cup over the weekend by defeating The Netherlands. The US controlled the entire match, much as they had for the entire tournament. They were tested to be...more

Farella Braun + Martel LLP

Battling Government Investigations Series – Cooperation and Voluntary Disclosure

It always comes when you least expect it – a government inquiry to investigate your business. While it may instill a sense of panic, there are steps you can take to make sure you’re in the best position possible when the...more

Thomas Fox - Compliance Evangelist

Day 11 of One Month to Better Investigations and Reporting-Investigative Challenges

Today, I want to consider some of the challenges you may well face during an investigation. I am once again joined by Jonathan Marks, a partner at Marcum LLP and well-known investigations expert. Beyond the basics, a company...more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Thomas Fox - Compliance Evangelist

Day 18 of One Month to Better Compliance Through HR- Using Promotions to Operationalize Compliance

The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antithetical to HR, the company...more

NAVEX

Compliance’s Role in Preventing the Next “WannaCry” Cyberattack

NAVEX on

The global chaos unleashed by the WannaCry ransomware virus reinforces that cyberattacks are not just the problem of IT departments. Compliance must play an integral part of any organization’s cross-functional cybersecurity...more

Thomas Fox - Compliance Evangelist

Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more

Thomas Fox - Compliance Evangelist

Day 7 Of One Month To Better Compliance Through HR - Six Principles For Compliance Incentives

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives. She posed it with the following question, “Are there mechanisms to enforce compliance...more

Thomas Fox - Compliance Evangelist

Day 6 of One Month to Better Compliance Through HR-Incentivizing Compliance

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – How has the company incentivized compliance and ethical behavior? How has...more

Thomas Fox - Compliance Evangelist

“Zen and the Art of Motorcycle Maintenance” – Lessons for Compliance

Robert M. Pirsig died last week. For anyone who went to college in the mid-70s, he was required reading in a variety of classes and disciplines for his seminal work Zen and the Art of Motorcycle Maintenance. There were a...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Compliance Through HR-the Role of HR in Operationalizing Compliance

This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more

Thomas Fox - Compliance Evangelist

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Thomas Fox - Compliance Evangelist

A Trip to the Dentist for Some Compliance Insight

I had to go to the dentist yesterday. I went for what I thought was filling repair but I had somehow forgotten that it was a wisdom tooth removal and a filling repair. I know you are thinking either (1) why does someone his...more

Thomas Fox - Compliance Evangelist

Hiring and Compliance: Evaluating Candidates and Setting Expectations

Today I want to talk about two different techniques that your HR function can use to help the compliance function by honoring two very different yet equally famous baseball players who died on Sunday. The first was Jim...more

Thomas Fox - Compliance Evangelist

Tribute to Conrad and Succession Planning in Compliance

The Horror! The Horror! Those are the seminal words of Mr. Kurtz, Manager of the Inner Station, in Joseph Conrad’s novel Heart of Darkness. Today we celebrate Conrad, Józef Teodor Konrad Korzeniowski, who was born on this...more

Thomas Fox - Compliance Evangelist

Hiring In Compliance, Part III – Presentation of Job Opportunity to Potential Candidates

This week I am presenting a series on hiring in the compliance industry based on interviews I did with Maurice Gilbert, the Managing Partner at Conselium Partners LP. Today, I want look at the presentation of the job offer to...more

Thomas Fox - Compliance Evangelist

BNY Mellon and Lessons Learned In Hiring Family Members – Part II

In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more

Thomas Fox - Compliance Evangelist

Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

Thomas Fox - Compliance Evangelist

Levi Strauss and Auditing of Third Parties

Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more

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