The United States healthcare industry poses an infinite number of risks when it comes to interactions with healthcare professionals.  Given the aggressive regulation and enforcement of prohibitions against kickbacks and referrals, healthcare companies have to devote significant resources and strategies governing interactions with physicians. First, healthcare provides, pharmaceutical and medical device companies have a variety of legitimate reasons for relationships with physicians.  They work closely...

Colleen Hurson, Of Counsel at The Volkov Law Group joins us for her first posting on the blog concerning export control reform measures applicable to the firearms industry. Colleen has substantial experience in handling export control and sanctions compliance for clients subject to the State Department’s ITAR regulations and Commerce Department’s EAR regulations. Colleen can be reached at [email protected]. This week the Trump Administration is...

Webinar: Anti-Corruption Compliance in Pharma and Medical Device Industries February 26, 2019, 12 Noon EST Sign up HERE FCPA enforcement against drug and device companies continues at a robust rate. Given the high-risk nature of pharmaceutical and medical device industries and significant interactions with foreign government officials, drug and device companies face a number of challenges in designing and implementing effective anti-corruption compliance programs.  Join...

We are living in a rapidly changing world (trite, I know) where companies have to focus on data privacy and security for a variety of reasons.  Consumers and constituents are concerned about the safety and privacy of personal and financial information.  In this era of “sharing” and posting of private information, consumers and constituents have broad and reasonable expectations concerning their personal and financial information....

As compliance programs (and the profession) continue to mature, there is growing interest in the need for measurement, monitoring and auditing of compliance programs.  This is a natural evolution in the lifecycle of a compliance program. Once a CCO has operationalized a company’s compliance program, the next challenge logically is to design strategies to ensure proper operation.   The elements of an effective compliance program include...

I was honored to be named as a Top Thought Leader for 2019 by Trust Across America. More importantly, I am privileged to share this honor with 91 global professionals from a broad spectrum of professionals involved in integrity and trust, leadership, culture, compliance and ethics, reputation and risk management, governance, communications, employee engagement, sales and customer service.  The Announcement in TRUST Magazine’s Winter 2019...

Managing your third-party risks requires a wide-angle view of your third parties.  What do I mean by that? Companies are hyper-focused on identifying risks during the onboarding process, the use of automated platforms to organize and conduct such screening, and continuous monitoring through an automated platform.  Such a perspective, however, is far too narrow in scope and scale.  Too many third-party risk management strategies ignore...

In a stark message, Justice Department prosecutors have brought the first criminal case for anti-money laundering violations against a broker-dealer.  Central States Capital Markets, LLC (Central States) agreed to pay a $400,000 penalty and entered into a deferred prosecution agreement (DPA) with the US Attorney’s Office for the Southern District of New York for violating the bank Secrecy Act. As set forth in the court...

There is no question that corporate leaders, senior executives, legal and compliance staff, and internal auditors recognize the value of an ethical corporate culture.  It is the latest “fad” in corporate governance, and it is a welcome development.  I have written extensively on this important trend and the value of a company’s culture of ethics and compliance. CEOs and corporate executives, however, have embraced this...

I had the honor of appearing with Julie DiMauro, a Regulatory Intelligence Expert, at Thomson Reuters Legal, in her regular videocast on important legal and regulatory issues. In our discussion, we review FCPA enforcement and compliance trends. The video is available HERE. Julie is a thought-leader in the regulatory and legal space. She is the Regulatory Intelligence Expert at Thomason Reuters Legal, and is a...