If you follow my blog, you know that I am passionate about the compliance profession. Chief compliance officers have unique talents, expertise and leadership qualities. CCOs are committed ethics warriors. No one else can claim that same mission. CCOs are the natural stewards of a company’s ethical culture. Of course, a company can appoint a separate chief ethics officer to distinguish between the ethics and...
David Friedman, an expert in workforce culture, joins us for a guest posting on the impact of the pandemic and workforce culture. David can be reached at www.culturewise.com. David is the author of Culture by Design: How to Build a High-Performing Culture Even in the New Remote Work Environment. As many workers flee their current jobs, burnout and lack of growth opportunities are being cited as...
Third-party risk management is a favorite topic for compliance professionals. And for good reason. Third parties create significant risks. To state the obvious, companies have less control over third parties than employees. But for many reasons companies engage third parties as a more effective solution than hiring employees. In this situation, risk multiplies exponentially. The third-party risk issue, however, has multiplied exponentially for a number...
This has been an interesting enforcement year. The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of political appointees has delayed the transition process. Consequently, enforcement has gotten off to a slow start. But companies would make a big mistake in embracing complacency or just waiting for enforcement to pick up before elevating...
The healthcare industry faces cascading risks – one risk flows to another with compounding financial results. Three generic drug companies just experienced this cascading liability. As part of the Justice Department Antitrust Division’s investigation of the generic drug industry, Taro, Sandoz and Apotex settled criminal antitrust cases by entering into a deferred prosecution agreement, paying a financial settlement and agreeing to cooperate with the ongoing...
Organizational risk does not exist in a vacuum – social forces have a direct and immediate impact on company risks, especially when it comes to employee conduct. Social media has transformed our society, making information sharing instantaneous. For companies, social media risks exist on internal communications platforms and on individual employee platforms outside of work. Many companies find the issue so difficult and complex that...
Chief compliance officers are creative professionals. This is one of many areas of expertise. But when it comes to corporate politics, many CCOs know how to package and promote their mission. CCOs faced real constraints and challenges during the pandemic. CCOs were challenged as to why compliance was an important function to preserve in the time of a pandemic which threatened many companies’ very existence. ...
The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution. This was not unexpected. Indeed, the Antitrust Division gave plenty of warning to companies that criminal prosecutions were on the horizon. Over ten years ago, DOJ brought civil cases to stop illegal labor market collusion. Out of an abundance of caution, DOJ recognized that it wanted to provide “fair warning” of...
In the second OFAC enforcement action released on the same day, September 27, 2021, Schlumberger Rod Lift, Inc. (“SRL”) (now d/b/a Lufkin Rod Lift, Inc.), and formerly a subsidiary of Schlumberger Lift Solutions LLC (“SLS”), a U.S. subsidiary of Schlumberger Curaçao, Netherlands, agreed to pay $160,000 to settle an OFAC violation of the Sudan Sanctions Program (since repealed in October 2017) stemming from one shipment...
In a pair of enforcement actions, here and here, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. Cameron agreed to pay $1.423 million to settle OFAC charges for providing services to the Gazprom-Neft Shelf for an Arctic offshore oil...
