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Do You Have an Insider Trading Compliance Policy?

Do You Have an Insider Trading Compliance Policy?

Just to make every compliance officer’s job a little bit more difficult, companies need to adopt and implement an insider trading compliance policy.  The Justice Department and the SEC have made headlines through its high-profile insider trading criminal prosecutions.  Underneath the radar screen, the Justice Department has been pursuing a large criminal investigation focusing on “expert networks,” in which consultants have been used, along with...

Join Me and Tom Fox in San Diego and Receive Free Copies of Our Books

Join Me and Tom Fox in San Diego and Receive Free Copies of Our Books

Please join me and Tom Fox for a complimentary breakfast seminar on September 25, 2012 in San Diego, California. The seminar is being sponsored by Kreller Group.  Everyone who attends will receive a free copy of my book, Corruption Crime & Compliance, and Tom’s book, FCPA Compliance and Ethics. Anti-Corruption Due Diligence Workshop: Practical Steps to Protect Your Company from Third Party and Joint Venture...

Subscribe to Corruption Crime & Compliance — E-Mail Delivery to Your Mailbox

Subscribe to Corruption Crime & Compliance — E-Mail Delivery to Your Mailbox

Have the latest posts on Corruption Crime & Compliance delivered to your mailbox.  No need to travel on the Internet.  It will be delivered to you immediately when posted.  The email sign up is on the lower right hand side of the blog.  Just enter your email address and you will receive email notifications of new posts!! Thanks for all your support.

Update on Data Privacy

Update on Data Privacy

Here is another guest post from Patrick Kellermann from Leclair Ryan.  His bio is here.  We looked earlier this week at Google’s proposed $22.5 million data privacy settlement.  See post here.   As Hurricane Isaac pummeled our shores, and the Republicans held their convention in Tampa, yet another headline on data privacy appeared — when it rains, it pours. District Court Judge Susan Illston granted Consumer Watchdog’s...

Colombia: The Land of Opportunity

Colombia: The Land of Opportunity

Colombia is a beautiful country and the people are amazing.  It is the land of economic opportunity.  The Free Trade Agreement, which was finally ratified by Congress, last year, became effective on May 15, 2012.  The United States has quadrupled exports to Colombia in the last four years, totaling $14 billion each year.  That number is expected to sky-rocket because of  the Free Trade Agreement...

Crisis Management Plans

Crisis Management Plans

When it comes to headlines, companies either love or hate the publicity.  There is no middle ground.  Companies face a number of risks which can easily turn into a “crisis.”  When they occur, a company needs to turn its attention to the crisis.  A comprehensive crisis management plan is a must have in order to navigate the risks and potential harm to the company. A...

2012 Antitrust Enforcement – A Big Year

2012 Antitrust Enforcement – A Big Year

The Justice Department’s criminal antitrust enforcement program has had some major successes.  In many respects, the Justice Department’s criminal antitrust program provides an example of what the FCPA criminal program may look like in the future.  Antitrust and anti-corruption investigations are closely linked and regularly cross-pollinate each other.  In many cases, compliance breakdowns may lead to foreign bribery and cartel behaviors.  Cooperating witnesses in an...

FTC and Data Privacy Compliance

FTC and Data Privacy Compliance

Patrick Kellerman from LeClairRyan (Patrick’s profile is here) responds to an article in Forbes asking if the recent $22.5 million FTC – Google settlement does more harm than good.  A copy of the Forbes article is here.  First, some background information: The FTC alleged Google violated the Consent Order reached in the Google Buzz settlement by misrepresenting its tracking cookie practices pertaining to users of the...

The LIBOR Scandal Unraveled

The LIBOR Scandal Unraveled

The LIBOR “scandal” could have far-reaching implications for financial institutions in the United States and global markets.  It is hard to know exactly how the issue will play out.  The Department of Justice is definitely gearing up to lead or play a significant role in a wide-ranging criminal and civil investigation.  The investigation focuses on traditional antitrust and fraud violations.  The implications for follow-on civil...

Social Media Risks and Compliance

Social Media Risks and Compliance

Companies continue to access social media sites to monitor employees and assess job applicants.  They do so in the face of increasing risks.  Federal and state laws and regulations are rapidly changing as social media use by individuals increases and the line between personal and business use of social media becomes fuzzier. Public reaction was strong when companies insisted that employees or applicants provide passwords...