Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Compliance Tip of the Day: COSO Framework
Compliance Tip of the Day: Internal Controls for GTE
Compliance Tip of the Day: Board Oversight on Internal Controls
Compliance Tip of the Day: Internal Controls for Third Parties
Compliance Tip of the Day: Implementing Internal Controls
Compliance Tip of the Day: Risk Assessments and Internal Controls
Compliance Tip of the Day: Issues for Internal Controls in International Operations
Compliance Tip of the Day: Top 4 Compliance Internal Controls
Compliance Tip of the Day: Discipline and Rigor in GTE Internal Controls
Compliance Tip of the Day: What are Internal Controls?
Testing Your Compliance Program
Regulatory vs. Business Compliance
Grupo Empresarial y Control … ¿a qué te cojo ratón?
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more
I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...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
In this post, we conclude our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the now recidivist Oracle Corporation. This enforcement action was concluded with the Securities and Exchange...more
Ericsson is having a tough time. First, in 2019, Ericsson settled FCPA charges with the Justice Department and the SEC for a total of $1 billion (with a B). Second, Ericsson had an independent compliance monitor appointed...more
In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...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
What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance program. The starting point...more
After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with...more
I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more
Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft, “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign Corrupt...more
Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft (DB), “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign...more
Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more
Shortly before announcing its comprehensive FCPA settlement with DOJ and the SEC, Pilgrim’s Pride agreed with the Justice Department’s Antitrust Division to plead guilty to price-fixing in the chicken processing industry....more
The SEC settled with J&F Investmentos (“J&F”) for approximately $27 million. Unlike the DOJ settlement, the SEC included JBS and Joseley and Wesley Batista in its enforcement action. The factual predicate for the settlement...more
In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more
Recently we saw one of the most blatant cases of bribery and corruption brought by the Department of Justice (DOJ) in the form of a guilty plea by Sargeant Marine Inc. (Sargeant Marine), an asphalt company, related to...more
At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more
Editors’ Note: This is the third in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed healthcare fraud in 2020. Up next: a look at...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more