The FCPA Paparazzi has done a great disservice to the business community.  Call it a complete lack of credibility.  Legal marketing has become confused in this day and age – marketing has now been turned into the “Fear Factor,” meaning that lawyers need to scare potential clients into hiring them.  That is flat out wrong.     Each week, new client alerts, client warnings and other...

For your weekend pleasure, I wanted to share with you my wife, Rosetta's blog: Sicily: Cuisine, Culture & Tradition.  Please check it out and bookmark it for future reference.  Sicily is a magical island with fantastic beaches, food, wines, and wonderful people.  I urge everyone to travel and enjoy Sicily.  If you cannot make it a travel destination, make a virtual visit through Rosetta's blog. http://sicilycuisine.blogspot.com...

Every company knows that its internal auditing function is the lifeblood of its compliance program.  Some companies carry that to an extreme by placing the overall compliance function in the auditing department.  As we all know, that is a mistake. Auditing plays a critical role in every compliance program.  Why?  For obvious reasons, internal auditors usually are the first to uncover improper payments.  So far,...

The Consumer Financial Protection Bureau continues to throw its weight around.  The CFPB is not shy nor is it reluctant to take on some of the biggest financial players in the industry.  The CFPB is still expanding its reach and its intended targets for investigation and prosecution. Recently, the CFPB issued its draft strategic plan for 2012 to 2018, which identifies for strategic goals and...

As if businesses do not have enough on their plate: the Justice Department and the Treasury Department have been increasing AML enforcement against banks and other “financial institutions.”  It is not a surprise because the Justice Department warned everyone they were going to increase AML enforcement, including non-traditional financial institutions. The Justice Department has flexed its muscles in this area.  It brought significant cases against...

I wanted to welcome Catelas as a new sponsor to Corruption, Crime & Compliance.  I have known Catelas for nearly five years and have been impressed by the quality of its products, the commitment of its leadership, and the innovative approaches it has developed to assist companies in enforcement and compliance. Catelas provides valuable software in the legal & compliance arena and is already being used by...

The Department of Justice continues to trumpet its healthcare fraud program.  Just last week, the Justice Department and HHS announced another nationwide sweep resulting in the arrest of 91 individuals. The Justice Department has dropped its “war on drugs” and replaced it with “war on healthcare fraud.”  The Affordable Care Act recognized that aggressive prosecution of fraud would help to reduce health care costs.  Even...

The fear of corruption can sometimes be overblown.  If corruption fears drive business decisions, the fear is winning and business loses. Global businesses sometimes decide not to enter a new market because of corruption concerns.  Such a decision is usually short-sighted.  It also reflects a fundamental governance failure – you can rest assured that the business failed to include compliance professionals in such a determination. ...

Hospital administrators should be nervous.  The Justice Department and HHS are out to pressure service providers, including hospitals and doctors, to reduce costs.  In Washington, hospitals and doctors are perceived to be a big part of the problem of rising health care costs: they gouge the system to line their own pockets. In September, Attorney General Holder and HHS Secretary Sebelius warned hospitals that they...

Stephen I. Siller from LeClariryan is our guest contributor today.  Stephen is a member of the corporate services and international transaction practices.  His bio can be viewed here. For international companies seeking to tap into the American market through U.S.-based acquisitions or existing subsidiaries, the cost of compliance slipups can be high indeed. This is true whether the parent is a tech start-up from Asia...