LRN’s annual Ethics and Compliance Program Effectiveness Report is an important yearly event. The report is often filled with important trends and observations. For compliance officers, there is always important trends and information to review. As we know, however, 2021 was no ordinary year. Instead, for many companies, the challenges of COVID-19 split the year into two – and LRN has followed suit. Its first...
NAVEX Global produces a number of important compliance program reports. NAVEX Global always has played an important thought-leadership role in the ethics and compliance field. NAVEX Global’s annual Incident Management Benchmark Report provides important data on employee engagement and reporting. A copy of the Report can be downloaded here. The Report is based on NAVEX Global’s massive incident reporting database connected to its hotline reporting...
Sometimes it takes a public event to remind corporate risk managers about the importance of effective risk management. While corporate risk management functions have become yet another “hot” topic or new-fangled response to corporate failures to prevent obvious risk, most organizations continue to wander in the world of reactive business planning rather than proactive prevention. It has been fairly obvious for years that most corporate...
Corporations are holding their respective breaths. SEC Chairperson Gary Gensler and his SEC colleagues are moving quickly to establish a regulatory framework for ESG disclosures. Climate change and diversity are the key issues surrounding this disclosure regime. The SEC initiative is easier said than done and presents a number of interesting issues that will have to be resolved. The SEC has invited comments on climate...
Over the last ten years, we have seen a steady increase in the coordination and cooperation among international prosecutors and law enforcement to prosecute bribery cases. In a recent example, the Justice Department unsealed criminal charges against two former diplomats from Chad for taking a $2 million bribe from Griffiths Energy International, Inc., a Canadian energy company. The indictment was originally returned in 2019 and...
The Justice Department continues to pile up victories out of the world soccer FIFA federation bribery scandal. Julius Baer Group, the Swiss banker, agreed to a three-year, deferred prosecution agreement (DPA) and to pay nearly $80 million to resolve money laundering charges. Julius Baer laundered approximately $36 million in bribes between February 2013 and May 2015 in which sports marketing companies bribed soccer officials for...
The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration. This enforcement lull occurred in the transition to the prior administration in 2016, and there is nothing to glean from it since it is a natural occurrence when a new Justice Department administration takes the reins of power. Last week, we had...
Andre Bywater and Jonathan Armstrong join us for a guest posting on the EU Speaking Up regime. André and Jonathan are lawyers with Cordery in London, United Kingdom, where they focus on compliance issues. André Bywater can be reached at [email protected] and Jonathan Armstrong can be reached at [email protected]. In 2019 the EU introduced new rules to enable whistleblowers to report about EU law irregularities...
Thank you to the brave men and women who have made the ultimate sacrifice. We honor their service, their courage, and their memories. Let us use this holiday to remind us all of our heroes and to honer them for their service.
When you look at the core of several major financial scandals, it is easy to point to problems with sales incentives and corporate culture. A company can rapidly grow due to the extraordinary performance of a company’s sales culture. In many cases, this sales culture creates real and significant risks for misconduct. To address such potential for misconduct, companies rely on internal controls to constrain...
