FCPA compliance has become the lifeblood of business.  Whether a company is seeking to acquire another company, or a company needs a loan from a bank, FCPA compliance is required.  Companies understand this fact and have steadily ramped up compliance programs.  A recent survey established that at least 50 percent of companies have increased spending on anti-corruption compliance.  FCPA issues now permeate every merger negotiation,...

Compliance officers are honest about the strengths and weaknesses of their compliance programs.  They are realists and mission-driven.  As such, they are always willing to consider and try new ideas and strategies. In recent FCPA settlements, the Justice Department has required companies to conduct a compliance assessment from a macro viewpoint in order to target certain high-risk areas for audits.  The idea is a good...

I am happy to welcome Tom Echikson from LeClairRyan to Corruption, Crime & Compliance.  Tom has practiced environmental law for 25 years and is based in Washington, D.C.  His bio is here.  He can be contacted at [email protected].   A question I often am asked is “What can and should our company do when it receives an information request from EPA or an EPA inspector shows up unannounced at...

The recent issue of SCCE’s Compliance and Ethics Professional Magazine includes Donna Boehme’s interview of me on compliance trends.  I was honored to be interviewed. A copy of the link to the article is here. I continue to promote the professionalism and integrity of compliance professionals.  My interview is a small contribution to this effort. Thank you for your support!!!  

Every company dreads a visit from an FBI agent with a grand jury subpoena or a search warrant.  I have previously outlined (here) how a company should prepare in advance for a search warrant and what steps to take when the FBI arrives on your doorstep. A grand jury subpoena should not be a “surprise” event in corporate life.  Given the ever expanding list of...

The need for effective due diligence has led to a mushrooming of alternatives – software systems, database checks, and due diligence companies with or without “boots-on-the-ground.”  In this environment, it is hard to keep your eye on the ball.  Everyone has lots of advice, lots of service alternatives, and lots of angles to play. Lawyers sometimes get in the way and sometimes they can help. ...

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Compliance officers are a confident bunch.  Yes, they can worry like all the rest of us, but in the end, they have faith that they can accomplish their mission. Forward thinking companies are recognizing the importance of empowering compliance officers and relying on their skills to build proactive compliance tools.  Companies are increasingly relying on compliance officers to “fix” the company’s problems – sometimes this...

Patrick Kellerman from LeClairRyan returns with a blog posting on data privacy and data security.  His profile is here. If you ask in-house counsel what keeps them up at night, the response invariably includes “data privacy and security.”  It is a cutting-edge compliance and enforcement risk.  As with any new or increasing risk, companies need to address the problem by building from the ground up. ...