Bobby Butler, a well-known and long-time compliance professional, joins Michael Volkov for a thought-provoking discussion on the rise of the compliance profession. Bobby has had a long and successful career in compliance. He provides important insights into the evolution of the compliance profession, strategies for building compliance programs and the future of compliance and the compliance profession.
Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable, and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so but they have to understand the risks involved and tailor appropriate controls and procedures...
LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael discuss several important findings in LRN’s 2023 Report: High-performing ethics and compliance programs rely principally on values to motivate and guide ethical and compliant behavior — LRN’s Report confirms again...
The Securities and Exchange Commission continues to rack up FCPA enforcement actions. In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former Chinese subsidiary. According to Clear Channel, the Department of Justice closed its FCPA investigation. Clear Channel, a San Antonio-based advertising company, paid bribes to Chinese government officials with cash, gift cards, first-class travel,...
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from bribery payments in Vietnam, Indonesia and India. Albemarle entered into a three-year non-prosecution agreement (“NPA”) with DOJ and agreed to pay a penalty of approximately $98.2 million and an administrative forfeiture of approximately $98.5...
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare institutions. Another federal agency, OFAC, yesterday announced that it had settled with 3M for $9.6 million over alleged violations of the Iranian Transactions and Sanctions Regulations. In another OFAC enforcement action, Emigrant Bank (“Emigrant”),...
The United States continues to suffer from the absence of a federal data privacy and breach law. Congress has tried for years to broker a deal here but has never been able to overcome strong lobbying forces — whether its high-tech, trial lawyers, law enforcement or other gadflies, the public continues to suffer. Instead, global businesses face a real mess, tracking data privacy laws state-by-state,...
The SEC is having a good year in prosecuting FCPA cases. The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year. DOJ, which has been relatively quiet so far this year, recently resolved the Corficocolombiana case, its first for the year. 3M’s conduct centered on payments for Chinese healthcare officials employed by state-owned enterprises to attend overseas...
Mary Shirley, a leading voice in the legal and compliance field, has just released her new book — Living Your Best Compliance Life: 65 Hacks & Cheat Codes to Level Up Your Ethics & Compliance Program. Order Mary’s New Book Here. Mary is a well-known advocate, speaker and compliance professional. She regularly speaks at Compliance events. She is mentor to the Compliance Profession. In this Episode,...
The Department of Justice has been relatively quiet this year in announcing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana (“Corfico”) and Grupo Aval settlement is the first in 2023 involving a corporate FCPA resolution. For the SEC, the Corfico and Grupo Aval settlement is the sixth corporate resolution in 2023. Corfico and its parent...
