Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
Volatile Times in Vapor Intrusion Regulation: A Legal and Technical Update
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
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
One of the key lessons I learned in doing the research for The Complete Compliance Handbook is how compliance programs best practices have evolved beyond the basic requirements laid out in the 2012 FCPA Guidance’s Ten...more
On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more
Deputy Attorney General Rod J. Rosenstein recently announced a revision to the U.S. Department of Justice (“DOJ”) policy on corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”). The revision codifies a pilot...more
In my last post, I began considering the Prong of the Evaluation of Corporate Compliance Programs (Evaluation) which was not present in the Ten Hallmarks of an Effective Compliance Program, the root cause analysis. ...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more
Today I continue a five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation....more
Today, I continue a five-part series on what a Chief Compliance Officer (CCO) needs to consider when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I am...more
Many Chief Compliance Officers (CCOs) came to the position from the legal department, internal audit or another professional discipline. These professions are technically focused and their training provides little to no soft...more
The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for...more