It is hard to understand what is really going on these days with the Serious Fraud Office and the UK Bribery Act.  Here in the US, the Justice Department and Securities and Exchange Commission are clear about their intentions and many of their policies.  That makes the work of the FCPA Paparazzi a lot more interesting.  I feel sorry for the UK Bribery Act Paparazzi,...

New companies are often frenetic – the power of the idea is what motivates everyone.  The corporate culture is defined by creating a new organization around an idea.  The key motivation is to be successful. In this environment, compliance is never a priority.  That makes sense – if the company does not make money, the company will quickly die.  Compliance is irrelevant if there is...

Companies face difficult decisions every day.  In the last ten years, federal law enforcement investigations have become more frequent.  The criminalization of civil or regulatory violations increases risks for companies and most importantly, senior executives and board members. The enforcement environment reflects the government’s increasing reliance on criminal prosecutions.  It is easy to see why – criminal prosecutions involve large fines and threaten individual corporate...

  A. Neil Hartzell, a shareholder at LeClairRyan, is our guest commentator today, and offers some good advice on False Claim enforcement and compliance strategies.  His profile can be read here.     If you learned of a way to cash in on a lotto-sized jackpot that offered better odds than any Powerball ticket, would you be interested? Given our society’s materialistic bent, you can bet...

Compliance professionals frequently cite “tone-at-top” as an essential component of a compliance program.  It sounds good and a few quick sentences on the topic is usually all that is provided when explaining what this means.  In reality, “tone-at-the-top” is not really just “tone-at-the top” it is a lot more.  I will try to be clear.  Most people think that tone at the top is satisfied...

The healthcare industry always has taken the lead in compliance issues, developing innovative compliance tools and programs.   Anti-corruption compliance borrows heavily from many healthcare compliance ideas. Healthcare companies are dependent on the government for revenues.   As the government plays a greater role in our healthcare system, healthcare companies can expect compliance to become even more important.   At the same time, the government is dedicating more...

Patrick Kellermann from LeClairRyan, an expert in e-discovery and data compliance issues, joins us again as a contributor.  His profile can be viewed here.  In all honesty, document collection and review during an internal investigation is not a very sexy issue.  It is not like interviewing techniques, strategy calls on how to conduct the investigation, or even like reporting to the Board on an investigation. Like...

Tom Cohn, a shareholder at LeClairRyan, is our guest contributor today.  Tom is a former Director of the Federal Trade Commission’s Northeast Region.  Tom’s full profile is here.     As we noted last week, the Consumer Financial Protection Bureau (“CFPB”) is fast becoming a powerful, important player in the consumer finance market.  It has broad powers to ensure compliance with consumer protection laws for big...

Today’s posting is written by Donna Boehme.  She  is an internationally recognized authority and practitioner in the field of organizational compliance and ethics, designing and managing compliance and ethics solutions within the U.S. and worldwide. As principal of Compliance Strategists LLC, Donna is the former group compliance and ethics officer for two leading multinationals and currently advises a wide spectrum of private, public, governmental, academic,...