Episode 66 -- Gifts and Hospitality Compliance and Best Practices
Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
This is the third in a series of articles in which members of BCLP’s White Collar team review the recent report of the House of Lords Select Committee’s, entitled “The Bribery Act 2010: post-legislative scrutiny”. Here we...more
As the compliance function has matured, Chief Compliance Officers have built important relationships with related functions that are critical to the compliance function. Over the last few years, we have seen the Justice...more
My question appears to be fairly obvious, right? This is not a question or a quiz of every chief compliance officer. Rather, this is a question for everyone but the CCO and compliance and legal staff. Think about it....more
It is important to remember that companies are required to implement an ethics and compliance program. Ethics should not ever be a segregated issue carved off from a compliance program. They walk hand-in-hand, and reinforce...more
BROKER-DEALER - FINRA Issues Notice Regarding SEC’s Approval of New NMS Stock Recording and Reporting Requirements Rule - On August 8, the Financial Industry Regulatory Authority issued Regulatory Notice 16-28,...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more
Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law). The U.S. government has...more
In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more