The SEC adopted rules to implement the new whistleblower program authorized by the Dodd-Frank financial reform bill.  In a 3-2 vote, following party lines, the SEC adopted the rules over a vigorous defense that the new program will undermine corporate compliance programs by financially rewarding whistleblowers who circumvent existing compliance program reporting requirements. The whistleblower office receives about 1-2 credible reports every day, according to...

As part of my continuing series on building an anti-corruption compliance program from scratch, we need to work on the next step in our continuing series.  In yesterday’s post I described the risk assessment process.  So, your Bible is now complete.  Your risk assessment outlines potential risks and covers the following: geographic areas of operation and levels of corruption in these countries; industry corruption levels and enforcement...

The importance of compliance officers in today’s business is on the rise.  This trend reflects the increasing importance of risk management and proactive compliance to minimize those risks. But there is more for a compliance officer to do then simply manage and minimize risks.  Indeed, the role of the compliance officer needs to extend into day-to-day business operations; the more this occurs the better off...

The importance of compliance officers in today’s business is on the rise.  This trend reflects the increasing importance of risk management and proactive compliance to minimize those risks. But there is more for a compliance officer to do then simply manage and minimize risks.  Indeed, the role of the compliance officer needs to extend into day-to-day business operations; the more this occurs the better off...

What if – and this is a big what if – your company is starting from scratch on its anti-corruption compliance program? Your company’s Code of Conduct includes a paragraph prohibiting foreign bribery and mandating accurate books and records, and says little more. Some companies are able to relate to these questions. At the outset, your company has to recognize a couple of reality checks...

One of the eleven defendants charged in the online poker criminal case in the New York has plead guilty and agreed to cooperate.  Bradley Franzen plead guilty in court today and admitted to assisting oinline poker companies to process their internet gambling transactions.  Mr. Franzen’s company aided the copnspiracy by matching online poker sites with electronic-payment processors.  He admitted that he matched such services and sought to...

One of the eleven defendants charged in the online poker criminal case in the New York has plead guilty and agreed to cooperate.  Bradley Franzen plead guilty in court today and admitted to assisting oinline poker companies to process their internet gambling transactions.  Mr. Franzen’s company aided the copnspiracy by matching online poker sites with electronic-payment processors.  He admitted that he matched such services and sought to...

Check out my article as a guest contributor on The FCPA Professor Site:   HERE

Check out my article as a guest contributor on The FCPA Professor Site:   HERE