Managing Sanctions Compliance
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
Compliance Tip of the Day: Superforecasting
Compliance Tip of the Day: The Last Mile
Key Takeaways From the OIG's New Compliance Guidance for Nursing Facilities — Assisted Living and the Law Podcast
Envisioning a Compliant Workforce
Updating the Research Compliance Handbook
The Election's Impact on the FTC Will Bring Big Changes, But Being Vigilant Must Remain a Priority
Navigating the NYDFS' Cybersecurity Guidance on AI — The Consumer Finance Podcast
The Future of AI Regulation and Legislation: 5 Key Takeaways
Investigations and Cognitive Interviews
Fraud Prevention Techniques for Nonprofit Organizations - Part 3
Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
A Third Party's Perspective on Third Party Risk
Implications of the SEC Cybersecurity Disclosure Rule
Privacy Issues from Third-Party Website Tags
The importance of the global supply chain has never been more apparent since the COVID-19 pandemic resulted in worldwide shortages of products and drove prices and inflation skyward. Supply chain disruptions have become the...more
Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there. By following the roadmap, companies may escape...more
HCCA's Healthcare Research Compliance Academy is a three-and-a-half-day intensive training program designed to help attendees increase their ability to manage effective research compliance programs. Our faculty of experts...more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
American Conference Institute’s 8th Asia Summit on Anti-Corruption stands apart as one of the best networking and compliance benchmarking opportunities in the APAC region. Each year, senior government officials from...more
June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more
The Situation: On April 30, 2019, the U.S. Department of Justice ("DOJ") released an updated version of its guidance document, "Evaluation of Corporate Compliance Programs," in an effort to "better harmonize" the document...more
Global companies that grow through a deliberate merger and acquisition strategy continue to face significant anti-corruption risks. The list of FCPA enforcement actions includes numerous examples of companies that settled...more
Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested...more
The election of President Trump contained more than a few positive signs for Private Equity (PE) firms. Promises of a lower corporate tax environment, a ten-percent tax holiday for funds parked overseas, large infrastructure...more
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more
On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past...more
The FCPA Guidance notes that one of the ten hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context. A company that does not perform adequate FCPA...more
When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...more
The energy industry is in turmoil from the drop in the price of oil from $100 down to around $50 per barrel. Many energy companies have laid off up to 30% of their workforce. What can you do from the compliance perspective...more
In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more
In this episode, I visit with Virna Di Palma on the newly released TRACE Matrix. This is an extremely useful tool to help companies evaluate a wide variety of corruption and bribery risks on a country by country basis. ...more
In this episode 88 of the FCPA Compliance and Ethics Report, I visit with noted internal controls expert Henry Mixon on the types of internal controls needed for third parties in a FCPA compliance program. ...more
FCPA risks are significant when companies acquire other companies. The Justice Department and the SEC have imposed "successor" liability on companies for past bribery violations committed by an acquired company. Pre-closing...more
In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices....more