Category: General

31 Oct, 2018

Japanese Electrolytic Capacitor Manufacturer Sentenced to Pay $60 Million for Criminal Price-Fixing

The Justice Department’s Antitrust Division had a slow year in criminal antitrust cases. There are a number of explanations for the slowdown in criminal cases – the most persuasive is that such a slowdown is part of normal case processing ups and downs, especially as several significant investigations (e.g. auto parts suppliers) are coming to a close. One criminal antitrust investigation is picking up speed...

General

30 Oct, 2018

Speak Up is Great – Is Anyone Listening?

Chief compliance officers face a mountain of tasks – it is easy to get overwhelmed. Add to the mix the fact that CCOs are under extraordinary pressure to “prevent and detect” potential violations of the company’s code and any law or regulation. When you think about it, that is quite a heavy responsibility. In the ebb and flow of ethics and compliance ideas, one constant...

General

29 Oct, 2018

Ethics and Compliance as a “Marketing” Program

Right up front, I want to confess. I am a lawyer, and I love being a lawyer. So forgive me for this posting and perhaps my narrow-minded view but I have to take a moment to express some concerns about ethics and compliance. I am continuing to hear CCOs, especially at global companies, who describe their ethics and compliance program as a “marketing” program or...

General

28 Oct, 2018

University of St. Thomas Law Graduate Programs in Organizational Ethics Compliance

Colleen Dorsey, JD, Director, Organizational Ethics & Compliance, University of St. Thomas Law, joins us for a guest posting on the University of St. Thomas Law graduate programs in Organizational Ethics and Compliance. Colleen can be reached via email at [email protected]. A Head for Law A Heart for Integrity Every business exists by virtue of the trust of its customers and employees. Without strong ethics, companies not...

General

24 Oct, 2018

Health Management Associates Pays Over $260 Million in Criminal and Civil Penalties for Pervasive False Billing and Kickback Charges

Healthcare Management Associates (HMA) settled criminal and civil charges with the Justice Department for illegal fraud and kickback schemes. HMA billed federal government healthcare programs for inpatient services that should have been billed as outpatient or observation services, paid illegal remuneration to physicians in exchange for patient referrals, and inflated charges for emergency department facility fees. HMA was acquired by Community Health Systems (CHS) in...

General

23 Oct, 2018

Doctor and Two Medical Equipment Officers Head to Jail for Illegal Kickback Scheme

The Justice Department’s commitment – resources and public statements – has continued at a steady pace in the Trump Administration. Some might diminish the effort by recognizing that fraud is so pervasive that it is like shooting fish in a barrel. In the end, however, criminal cases require investigation, organization, resources and hard work. As you would expect, Florida is a prime geographic target for...

General

22 Oct, 2018

Managing Your Supply Chain: Turning “Do No Harm” Into “Doing Good”

I am definitely an optimist. Frankly, there is no alternative. Pessimists, by definition, ensure that the result they fear will occur. Another way of saying the same thing – karma is destiny. Chief compliance officers see the world in terms of risks – they share a worldview with lawyers who are always asked to examine the worst case scenario. For some reason, worst case scenarios...

General

21 Oct, 2018

NAVEX Global Releases 2018 Third-Party Risk Benchmark Report

NAVEX Global has issued its Third-PartyBenchmark Report. (HERE). The NAVEX Global Report contains important insights and data concerning ethics and compliance programs and third-party risk management strategies. I was pleased to assist NAVEX Global in preparing the 2018 Benchmark Report. Knowing how to appropriately define, screen and monitor your third parties is essential to minimizing risk. New industry benchmarks, along with the expert guidance provided in...

General

19 Oct, 2018

Sign Up for November 8, 2018 NAVEX Global Ethics and Compliance Virtual Conference

November 8, 2018 Sign Up HERE NAVEX Global has announced its annual Ethics and Compliance Virtual Conference. The schedule of sessions and speakers is here. The ECVC is the world’s largest compliance-focused conference. Created for professionals across Ethics and Compliance, Legal, Human Resources, Audit, Risk Management and Corporate Training, this online event is your best resource to learn the top issues and best practices affecting your...

General

18 Oct, 2018

JP Morgan Chase Bank Settles “Old” Sanctions Case for $5 Million

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime, OFAC is beginning to clear some of the enforcement matters that have been pending. JP Morgan Chase agreed to a $5.2 million settlement with OFAC for 87 apparent violations from the processing of...