News & Analysis as of

Supply Chain Dept. of Justice

Dietary Supplement & Cosmetics Legal Bulletin | October 2017

by Shook, Hardy & Bacon L.L.P. on

The use of beauty products is “an understudied source of environmental chemical exposures” with a disparate effect on women of color, George Washington University and Occidental College researchers argue. Ami R. Zota, et al.,...more

Soft Skills in Remediation: Part I – The Gatekeepers

by Thomas Fox on

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

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

by Thomas Fox on

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

The naked truth: Why your supply chain could leave you exposed

by Dentons on

If you are a business owner dealing with suppliers, you are potentially at risk of penalty for corruption related offences....more

Volkov on the Evolving Standards for Compliance Programs

by Thomas Fox on

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Rethinking Stakeholder Engagement for the New Millennium – Part I

by Thomas Fox on

What does stakeholder engagement mean in the 21st century? How has the topic gained such traction over the past few years? What is the role of the compliance professional in stakeholder engagement? How does increased...more

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

by Thomas Fox on

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

Sounding the Alarm: White House Agency Warns of Decreasing Competition Across U.S. Economy

by BakerHostetler on

The Council of Economic Advisors, a White House agency charged with advising the president on economic policy, recently issued a report, Benefits of Competition and Indicators of Market Power, addressing the state of...more

Food Safety Criminal Prosecutions: When Compliance is a Matter of Life and Death

by Michael Volkov on

Over the last ten to twenty years, we have witnessed the expansion of federal criminal prosecution of health and safety matters. Environmental and food and drug regulatory enforcement has been supplemented by aggressive...more

Five on Friday: Five Recent Developments that We’ve Been Watching Closely

There continue to be regular developments in the business and human rights field that warrant attention from both companies and their stakeholders. New legislation and regulation, shifting policy positions, and developments...more

Calculating the Incalculable: Reputational Damage (Part I of III)

by Michael Volkov on

Today I am beginning a three-part series on reputational damage. The first part tries to define the term “reputational damage;” the second part focuses on managing threats to a company’s reputation and the final posting...more

What Goes Downhill May Go Uphill in FCPA Compliance

by Thomas Fox on

Usually the question I am posed is how far down the chain must you go in your due diligence to ensure that your suppliers are in compliance with the Foreign Corrupt Practices Act (FCPA). I would pose that now, after the...more

California Department of Justice Seeking Information on California Transparency in Supply Chains Act Compliance

by Dorsey & Whitney LLP on

The California Department of Justice is sending companies informational letters regarding their compliance with the California Transparency in Supply Chains Act....more

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

by Thomas Fox on

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

Mandatory Training for Third Parties – Effective or Protective?

by NAVEX Global on

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

Edison, The Phonograph And Supply Chain Audits

by Thomas Fox on

Today we celebrate Thomas Edison. It is not his birthday but the 127th anniversary of Edison announcing his first recording invention, the phonograph. ...more

Honor Our Veterans And Compliance In The Supply Chain

by Thomas Fox on

Today is National Remembrance Day for Veterans who served their country and across the world. In the US we call it Veterans Day....more

Perils Of The Global Supply Chain Series, Part 3: Groundbreaking ‘Honey Laundering’ Sting Signals New Era In Supply Chain...

by Perkins Coie on

Supply chain compliance is on the government’s enforcement radar like never before. If the recent Executive Order on Trafficking in Government Contracts and final SEC Conflict Minerals Rules were not notice enough, the...more

Happy Birthday FT and Welcome Hanson Wade

by Thomas Fox on

Yesterday celebrated an auspicious anniversary as it was the 125th anniversary of the British newspaper, the Financial Times (FT), its first issue having been delivered on February 13, 1888. In England, and across the world,...more

Compliance in the Supply Chain – The Lesson of Gibson Guitar and the Lacey Act

by Thomas Fox on

I thought about the Astros futility when reading about the Criminal Enforcement Agreement (CEA) entered into by Gibson Guitar Corp (Gibson) for violations of the Lacey Act, which is a 111-year-old law, originally enacted to...more

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