Fine-Tuning Your Anti-Corruption Compliance Program  October 10, 2013 12 Noon – 1 PM EST  Register: Here In this era of aggressive FCPA enforcement, companies are adopting anti-corruption compliance programs. The Department of Justice and the SEC have warned companies against adopting “paper compliance programs” without meaningful and consistent implementation. In recent weeks, FCPA enforcement has focused on hiring of relatives of foreign officials and corruption...

Healthcare Fraud Compliance  October 9, 2013 12 Noon – 1 PM EST Register: Here The Department of Justice and HHS-OIG have focused on prosecution of healthcare fraud. The government has effectively used a complement of criminal and civil tools to secure large fines and penalties. Healthcare providers, including hospitals, doctors, home healthcare, nursing homes and other suppliers are aggressively investigated and prosecuted. In this era...

It is almost a government rite of passage – when a new leader takes the reins, the chessboard has to be reorganized to reflect the new leader’s “new priorities.”  When it comes to the SEC, and the new Chairwoman Mary Jo White, the “new priority” is the return to an oldie but goodie – accounting fraud. Let’s face it – the SEC does it best...

In a fitting tribute to the departing Deputy Assistant Attorney General Scott Hammond, the architect of the Antitrust Division’s criminal enforcement plan, the Department of Justice last week announced a record criminal settlement in its largest criminal investigation ever – the auto parts investigation. Nine Japanese companies and two executives agree to plead guilty and pay fines totaling more than $740 million for a price...

I would like to think of myself as an advocate for the Chief Compliance Officer.  It is easy to see why the CCO and the General Counsel should be separate individuals but close colleagues who depend on each other.  Separation and dependence is a hard act to put together in one relationship but it can be done. Just because a company has set up the...

The privilege to serve on a corporate board is no longer the cushy experience of our forefathers.  The increase in enforcement actions has led to a dramatic change in the role – and the risks – facing corporate boards. Companies dread hearing lawyers recommend the need for an internal investigation.  Alarm bells and whistles go off and corporate board members have to take a deep...

The growth of the compliance industry has included an increase in business surveys and specific attitudes towards corruption and compliance programs.  They are interesting to read, not as the definitive source of business compliance trends, but as one of several pieces in the compliance puzzle. I try to follow most of the significant compliance surveys and look for interesting issues to highlight.  Every survey is...

Anti-Corruption Compliance Program Audits  October 1, 2013, 12 Noon – 1 PM EST Register: Here Companies are devoting more resources to monitoring their compliance and ethics programs.  Anti-Corruption compliance program audits are an important tool for companies to use to monitor the effectiveness of its compliance program.  There are a number of important issues to address in preparing for and conducting an audit. Join Michael Volkov,...

The Antitrust Division and practitioners live in their own world.  It is part of the fabric when you work in the Antitrust Division – it is an entity unto itself within the Department of Justice.  For years, the Antitrust Division has been able to fend off greater control by the DOJ heirchy by arguing that protecting competition and markets is a very specialized mission, requiring...

You never see the words “poor” and “JP Morgan” in the same sentence.  It is a historical oxymoron – the words do not fit together.  However, if you have been following the headlines lately – you have to think to yourself, “poor JP Morgan.”  How can a company get hit so hard, so many times, and expect to survive? The timing could not be any...