Earlier this year, at a Houston FCPA Conference, the Justice Department and the SEC predicted that their aggressive enforcement policies would continue.  So far this year, they have been right on the mark.  Even with additional litigation responsibilities in the Shot Show case and three pending criminal cases set for trial this spring and summer, DOJ’s recent  FCPA settlements continue at a record pace and...

            On April 8, 2011, Johnson & Johnson settled criminal FCPA allegations and agreed to “pay a $21.4 million penalty to resolve criminal FCPA charges with the DOJ and $48.6 million in disgorgement and prejudgment interest to settle the SEC’s civil charges.”               As part of the settlement, Johnson & Johnson agreed to a Deferred Prosecution Agreement (DPA) which included two important attachments outlining compliance...

            On April 8, 2011, Johnson & Johnson settled criminal FCPA allegations and agreed to “pay a $21.4 million penalty to resolve criminal FCPA charges with the DOJ and $48.6 million in disgorgement and prejudgment interest to settle the SEC’s civil charges.”               As part of the settlement, Johnson & Johnson agreed to a Deferred Prosecution Agreement (DPA) which included two important attachments outlining compliance...

Since we are closing in on the end of 2011, it is time to join the crowd and select the person of the year award — even in our narrow field of reference: compliance.  For me there is no question — it is the chief compliance officer.  There is no other position in a company which has taken on more significance. All you need to do is consider...