In the era of global antitrust cartel enforcement, antitrust practitioners often scratch their collective heads and ask why is antitrust compliance so ignored by government enforcement agencies. Instead of promoting antitrust compliance programs by offering real and meaningful incentives, antitrust enforcement agencies offer no carrots to companies to enhance their antitrust compliance program. Antitrust enforcement leaders often promote a simplistic argument – if a company...

Chief Compliance Officers are the rising professional stars in the corporate employment landscape (along with IT professionals who have practical perspectives). The profession is at an important test – where will the profession go from here and what steps do CCOs need to take to prepare for these challenges? I always say that CCOs are a confident group of people. They are committed to not...

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick analysis, rapid descriptions, and targeted thinking. It is one of the downsides of our new information age. In fairness, I have to admit there are significant upsides to our...

Like Tinkers to Evers to Chance completing a double play, compliance programs need to maintain important links among three key elements – its complaint system, the handling of such complaints, and the publicized resolution of such complaints to encourage its Speak Up culture. Complaint Reporting Channels: Many companies have more than one avenue for officers, managers and employees to complain. That is a good thing....