Compliance Perspectives: Volkswagen's Transformation
Daily Compliance News: March 3, 2020, the Devil’s Advocate edition
Compliance into the Weeds-Episode 62, Sentencing of VW Employee Oliver Schmidt
Day 20: What Does Innovation in Compliance Look Like?
Drug giants Pfizer and Mylan have inked a deal that will merge the former’s off-patent drugs with the latter’s generics business, a tie-up that creates a mammoth global seller of lower-priced medicines....more
The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more
The Justice Department’s continuing lack of individual criminal prosecutions in the FCPA arena continues to raise serious questions. DOJ’s issuance of the Yates memorandum was seen as a new and important reiteration of DOJ’s...more
When Regulatory Failings Turn Criminal: Car Edition Redux - Why it matters: To paraphrase the famous quote from the film “All About Eve”: Fasten your seatbelts, it’s going to be a bumpy car ride. In the first part of...more
In this newsletter, we provide a snapshot of the principal Asian, US, European and selected international governance and securities law developments of interest to Asian corporates and financial institutions. ...more
Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
One of three counts in Volkswagen’s recent $4.3 billion guilty-plea was for obstruction of justice arising from a litigation-hold botched by house counsel. As VW prepared to admit the defeat-device problems to US...more
Corporate misconduct occurs in a variety of forms. Starting with the basic truism – companies act through people, and when companies engage in misconduct it requires the coordination and collaboration of multiple actors. The...more
That may well be the line most used by Volkswagen (VW) executives after the arrest of their fellow executive, Oliver Schmidt, this past week at the Miami airport. According to an article in the New York Times (NYT), entitled...more
Last week, the Justice Department reported a guilty plea in the VW emissions scandal prosecution. By this one announcement, DOJ signaled that it is planning to build a bigger case against VW. Ironically, the Justice...more
Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more
I hope everyone had a great 4th of July. One of the small pleasures I take each week is reading the New Yorker’s Cartoon Caption contest. I have entered most weeks for the past 10 years or so when the spirit moved me with a...more
I conclude my week honoring the 400th anniversary of the death of Shakespeare by using my favorite character in all his work to introduce today’s post. He is The Fool from King Lear. Of Shakespeare’s many theatrical...more
There is no dark side of the moon really. Matter of fact it’s all dark.” If you went to college in the 70s or 80s (or maybe even the 90s) you know what the next album is, Pink Floyd’s Dark Side of the Moon. For in the...more
Welcome back my friend; To the show that never ends. Except it did last week, when Keith Emerson died. He was the Emerson in Emerson, Lake & Palmer aka ELP. Emerson was one of the greatest keyboardists of his or any...more
One of the areas where my thinking has evolved in the compliance arena is around the area of reputational damage. Of course commentators, such as Andrea Bonime-Blanc, have written and spoken about preventing damage to a...more
Today, we conclude our week long exploration of the original Star Wars trilogy, all posted in conjunction with three podcasts, subtitled May The Podcast Be With You, where we use one movie as a staring point to review Foreign...more
Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more
"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more
Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red Flag Group, at the SCCE...more
Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more
I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other...more
In the movie Margin Call, Jeremy Irons intones that there are three ways to win in business: (1) be the smartest; (2) be the fastest; and (3) cheat. I am currently out at the SCCE 2015 Compliance and Ethics Institute and as...more
Today, October 2, is the first Friday in October so I begin my annual month of Friday HorrorFest Film highlights. This year I wanted to highlight the films of one of the great unknowns of horror films, Val Lewton. Lewton, a...more