News & Analysis as of

Training The Foreign Corrupt Practices Act Dept. of Justice

Compliance Man Goes Global-Episode 4-Training

by Thomas Fox on

Welcome to Episode 4 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on typical myths and mistakes regarding compliance trainings. In each podcast, we take...more

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

by Jones Day on

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

New Guidance from the DOJ on Your Compliance Program

by NAVEX Global on

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

Dave Edwards, the Doomsday Defense and Execution in Compliance

by Thomas Fox on

Baker Hughes Inc. Chief Compliance Officer (CCO), Jay Martin, often says that execution is where the rubber meets the road in compliance. I thought about all of that in the context of some of the pronouncements the Department...more

Compliance Training, Part I

by Thomas Fox on

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

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

3 Ways to Improve Compliance Training

by Michael Volkov on

As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

What the Government Expects to Find in an Anti-Corruption Compliance Program

by Dentons on

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

by Thomas Fox on

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

by Dechert LLP on

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

Waking Up to Massive Third Party Risk Exposure: Critical Issues To Address

by NAVEX Global on

A little over a year ago the Rana Plaza factory collapsed and 1,100 garment workers died. This human disaster resulting from questionable construction practices and workplace safety issues focused the eyes of the world on the...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

by Michael Volkov on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

by Thomas Fox on

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...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

More Compliance Lessons From The Asiana/SFO Crash Investigation

by Thomas Fox on

I have long been interested in the intersection in the changes in attitude regarding safety in the workplace by corporations and the changing attitudes on doing business through bribery and corruption. As a trial lawyer...more

Making Your Training Program Effective

by Michael Volkov on

Returning to the theme of profound grasps of the obvious, compliance officers face numerous challenges where they need creativity and persistence. ...more

A Prescriptive Guide To Third Party Risk Management

by NAVEX Global on

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Improving Your Anti-Corruption Training Program

by Michael Volkov on

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA

by Thomas Fox on

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

by Thomas Fox on

What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more

How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)

by Thomas Fox on

Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the...more

The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program

by Thomas Fox on

Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last...more

NFL Replacement Referees-the Lessons of Training Temporary Employees

by Thomas Fox on

The short autumn of our discontent is over as the United States has ended one of its greatest national convolutions of recent memory. Am I speaking of the attack on the US Consulate in Libya; the current stalemate of US...more

24 Results
|
View per page
Page: of 1
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.