I attended the SCCE’s recent Utilities and Energy Compliance conference in Houston. It is always a great meeting with terrific speakers and content. I was fortunate to attend a session, Taking the Pulse of Corporate Culture, presented by Amy Lilly from CenterPoint Energy and Steve Helm from NAVEX Global. A copy of the slides is here. Their presentation focused on how to build tools to...
Forgive me for taking a step back to address an important challenge in creating a culture of compliance. I know this may sound obvious but in today’s “toxic” political environment it is important to point out some factors that may be beyond the influence of a corporate culture, its leadership and its compliance team. I have consistently ignored commenting on political issues and will continue...
FCPA enforcement actions run the gamut of fact patterns and structured resolutions. We are in the midst of a transformation in the overall settlement environment with an expected increase in individual prosecutions. On the one side, we have a tough and comprehensive DOJ and SEC settlement against VimpelCom. The conduct within VimpelCom was pervasive and occurred at every level of the company, including the board....
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My colleague and good friend, Tom Fox, has released a new book: Effective Leadership Skills in Compliance — CCO 3.0 and Beyond. Tom is a leader in the compliance field and offers compliance practitioners and other professionals important insights on anti-corruption compliance and corporate governance issues. Tom’s latest book is another important contribution to the compliance field. Again, Tom is able to address important trends...
When commentators criticize the FCPA for its broad coverage of international business operations, these same commentators would have real trouble with the US Anti-Kickback statute. Talk about broad coverage and then complicate it with specific exemptions that are challenging to interpret and apply. When it comes to fraud enforcement in the healthcare industry, the Justice Department wields a mighty stick – the False Claims Act....
Medical device and pharmaceutical companies know the risks of conducting business in China. Company after company has had to settle FCPA enforcement actions in China. Many of these enforcement actions include fact patterns that are pretty consistent. At the heart of these bribery cases are distributors who are used to funnel bribery payments to healthcare professionals. The expectations and modes of operation are fairly consistent...
Over the last ten to twenty years, we have witnessed the expansion of federal criminal prosecution of health and safety matters. Environmental and food and drug regulatory enforcement has been supplemented by aggressive criminal enforcement. In the last few years, we have seen some landmark criminal cases involving companies and executives for food safety violations. Compliance programs in these high-risk industries can literally be a...
When compliance officers read about a major Justice Department settlement action, we can all hear the collective sigh of relief – “Thank goodness, that did not happen here in my company.” The recent Olympus settlement is another in a long line of cases where any shred of corporate culture of integrity has been replaced with a culture of bribery and kickbacks, or other kids of...
