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. ...

Have the latest posts on Corruption Crime & Compliance delivered to your mailbox.  No need to travel on the Internet or click on a Tweet — each posting 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. Thanks for all your...

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. ...

I know I am not supposed to say this but compliance can be simple.  That sounds like heresy but it is not.  A person’s intelligence is always reflected in their ability to explain complex topics in simple terms.  You may be the smartest person, the greatest thinker of all time, but in the end. if you cannot translate those great thoughts into simple ideas, which...

I am honored to welcome back Donna Boehme for today’s posting. Donna 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...

Companies discover FCPA violations all the time – most are small and few are big.  Most companies learn of these violations when implementing or upgrading their compliance program.  Typically, FCPA violations are discovered in the aftermath of an acquisition (months or even years after the acquisition), or in a company’s failure to implement adequate controls and supervision of their third parties and/or distributors. When discovered,...

The financial recoveries for healthcare fraud are staggering.  The Justice Department and Health and Human Services (Office of Inspector General (“OIG”) and Centers for Medicare and Medicaid Services (“CMS”)) regularly trumpet another round of healthcare fraud arrests and prosecutions.   They have turned healthcare fraud prosecutions into a cottage industry with phenomenal results. But who is committing all of this fraud?  A recent Government Accounting Office...

Benchmarking is a valuable tool because it gives you a window into industry practices.  Compliance professionals have to be careful how they use benchmarking information.  Falling into a benchmark should not necessarily give someone comfort.  It is better to develop your own “personal” benchmark – what you think the company needs, and the reasons for the details of your program. Take for example a recent...