News & Analysis as of

Whistleblower Hotlines Foreign Corrupt Practices Act (FCPA)

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance

King & Spalding on

On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas.[i] In issuing the new document...more

NAVEX

Advantages of a Whistleblower Hotline Reporting Systems: Understanding the Impacts of Internal v. External Reporting

NAVEX on

I interviewed Dr. Kyle Welch, Assistant Professor at George Washington University (GWU), on his recently released paper, co-authored with Stephen Stubben, Associate Professor from The University of Utah, entitled “Evidence on...more

NAVEX

Setting the Tone for Bribery & Corruption Disclosure

NAVEX on

Take a look at the contexts of the top-10 FCPA fines of all time and you will soon spot a trend: mostly European-based organisations where corrupt activity has been uncovered within the day-to-day running of the business....more

Thomas Fox - Compliance Evangelist

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Thomas Fox - Compliance Evangelist

Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues

Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more

NAVEX

Compliance Paid for Itself in Many Ways in 2016

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“A culture of ethics ties long-term performance to the interests of long-term stakeholders.” — Larry Fink, Chief Executive of Blackrock The quote above was mentioned by Timothy Erblich, CEO of Ethisphere, at the...more

Thomas Fox - Compliance Evangelist

Hallmark 8-Confidential Reporting and Internal Investigations

The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more

K&L Gates LLP

How to Conduct Internal Investigations Outside the United States

K&L Gates LLP on

Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

The Volkov Law Group

Reminders from the Goodyear FCPA Settlement

The Volkov Law Group on

FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more

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