Corruption, Crime & Compliance

Featured Articles:

3 Jun, 2020

DOJ Revisions to Corporate Compliance Guidance: Training, Third-Party Risk Management, Mergers/Acquisitions and Data (Part II of II)

DOJ is catching up to compliance officers and evolving best practices. Say what you want, DOJ is behind the curve of the compliance industry. But you have to give DOJ credit – they are moving quickly to update its Guidance. Compliance is a fast-moving profession – innovation and technology continue to define the industry. Compliance officers are willing to embrace change and the industry is...

General

2 Jun, 2020

DOJ Revises its Corporate Compliance Guidance (Part I of II)

If anyone thought that DOJ was planning to relax its expectations regarding corporate compliance programs, forget it – DOJ has removed all doubt. In an announcement on Monday, June 1, 2020, DOJ released revised guidance, Evaluation of Corporate Compliance Programs, June 2020. DOJ issued the new guidance to reflect its own experiences and feedback from the compliance and business community. According to Assistant Attorney General...

General

1 Jun, 2020

Drug and Medical Device Fraud Risks Increase in Pandemic Era

The drug and medical device/testing industry is under significant pressure to develop new products to address the COVID-19 pandemic. The federal government is increasing spending and support of drug and device companies in anticipation of developing a new vaccine, treatment products and testing. As a result, pharmaceutical, medical device and diagnostic and laboratory tests will be subject to federal scrutiny and monitoring for proper use...

Podcasts

31 May, 2020

Episode 144: A Review of Criminal Charges Against Paul Kruse, the Former CEO of Blue Bell Ice Cream

Paul Kruse, former CEO of Blue Bell Ice Cream, was recently charged with criminal charges stemming from the sale of contaminated ice cream, resulting in the death of three persons. Kruse was aware of serious safety and contamination issues arising from the production of Blue Bell ice cream. Notwithstanding his knowledge, Kruse ignored safety concerns and withheld critical information from its customers and consumers. In...

General

29 May, 2020

A Window into Boeing’s Defective Culture (Part III of III)

Boeing is still under investigation. A grand jury is investigating potential safety and obstructions allegations. Congressional investigations are continuing. Civil litigation surrounding the 737 Max are continuing. Boeing’s long path out of this nightmare appears to be rocky and filled with continuing risks, financial harm and reputational risks. In reviewing the wreckage surrounding Boeing’s culture and safety performance, public disclosure of over 100 pages of...

General

28 May, 2020

Boeing and the 737 Max Scandal (Part II of III)

Boeing’s 737 Max problems began over ten years ago. Facing competitive pressure from Airbus, Boeing embraced the 737 Max as its competitive savior. After two horrific crashes killing a total of 346 people, the FAA ordered the grounding of the 737 Max. Despite the grounding, Boeing produced another 400 737 Max airplanes before ceasing all manufacturing of the airplane in January 2020. The two plane...

General

27 May, 2020

The Boeing Scandal and the Demise of a Corporate Culture (Part I of III)

When a company suffers from serious misconduct, the source of such a failure usually lies in its corporate culture. I know this theory sounds relatively obvious, but bear with me here. The CEO and senior management and the corporate board are responsible for creating, oversight and monitoring of a company’s culture. Corporate boards and senior management work together, communicate regularly and should set an example. ...

General

25 May, 2020

Insights from the 2020 NAVEX Global Hotline and Incident Management Report

NAVEX Global produces a number of valuable compliance reports. Aside from its annual Third-Party Risk Management Report, NAVEX Global’s Hotline and Incident Report is always valuable given its leadership role in the hotline and incident management industry. The NAVEX Global Report is based on 2019 data before the pandemic occurred. Nonetheless, the insights are helpful and provide important insights that can be applied in a...

Podcasts

24 May, 2020

Episode 143 — The Boeing Safety Scandal and the Demise of Boeing’s Corporate Culture

Boeing Airlines was the leader in safety and financial success. Unfortunately, Boeing has suffered a significant fall from grace as a result of its 737 Max safety record and two devastating crashes in Indonesia and Ethiopia. The Boeing safety scandal has had a devastating impact on Boeing’s performance and uncovered a corporate culture that has been obsessed with financial performance to the detriment of safety...

General

21 May, 2020

Beneficial Ownership: Identification and Mitigation (Part IV of IV)

We are finally reaching the end of the road on the beneficial ownership path. In this last posting on the issue (for now), let’s start with a third-party population (third parties, vendors, suppliers) which have been classified into three categories, the first two of which fall into high-risk (foreign government interaction/representation and government ownership). The bulk of the population, usually around 80 to 85 percent...