Corruption, Crime & Compliance

Featured Articles:

15 Sep, 2022

False Claims Act Round-Up — DOJ Continues Aggressive Prosecution of Healthcare Fraud

The Biden Administration warned the healthcare industry that it would aggressively prosecute fraud cases. The Justice Department is executing on that promise and doing so with great success. Week after week, we read about False Claims Act settlement with multi-million dollar penalties. We barely hear much about healthcare compliance innovation and strategies — the industry is clearly treading water when it comes to proactive compliance...

General

13 Sep, 2022

The Disconnect Between Human Resources and Compliance

We can all remember those instances of matchmaking in our past — we were confident our friends, if they met each other, would fall in love and even get married. We believed that these two separate friends were “meant” for each other. In the compliance context, I always expect Human Resources and Ethics and Compliance to be a perfect match. They have so much in...

General

13 Sep, 2022

Civility and Corporate Culture

We live in a challenging time — yes, another profound grasp of the obvious. From my narrow perspective, there are two significant trends occurring at the same time — people are angry and more willing to express their anger and frustration in situations, while others appear to be embracing empathy, kindness and increased concern for others. I know this sounds circular but hear me out....

General

12 Sep, 2022

Corporate Culture = Talk + Action

Corporate culture is all the rage now, meaning it is an often used topic to signal commitment, sensitivity to issues of employee concern, and an awareness of governance trends. In practice, as we all know, culture is not just about words — it is about action. As the often repeated phrase goes — talk is cheap. On the issue of culture, talk is not only...

Podcasts

11 Sep, 2022

Episode 246 — NAVEX’s Annual Global Hotline Benchmarking Report

As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends. Each year, NAVEX issues an important report on current trends in employee reporting, whistleblowers, internal investigations and potential retaliation. NAVEX’s most recent report is interesting. NAVEX’s database consists of 1.37 million reports made in 2021 at organizations around the world. In this Episode, Michael Volkov...

General

8 Sep, 2022

NAVEX Issues 2022 Ethics Hotline Benchmarking Report: Whistleblower Reporting Rates and Retaliation Increase

As the leading hotline provider in the global market, NAVEX is in the unique position of collecting and analyzing employee reporting trends. Each year, NAVEX issues an important report on current trends in employee reporting, whistleblowers, internal investigations and potential retaliation. NAVEX’s most recent report is interesting. NAVEX’s database consisted of 1.37 million reports made in 2021 at organizations around the world. Initially, NAVEX sets...

General

7 Sep, 2022

U.S. Sentencing Commission Report: Corporate Prosecutions Decline and Ethics and Compliance Programs Increase

The proper balance in corporate prosecutions remains a tricky issue. On the one hand, many argue that large fines and penalties against corporations are needed to deter criminal conduct, while others contend that shareholders bear the brunt of such penalties while corporate actors escape punishment. In the most cynical sense, some argue that corporate fines are simply the cost of doing business. The pendulum swings...

General

6 Sep, 2022

Justice Department Announces FCPA Charges Against Two Individuals for Bribery of Marshall Islands Officials

The Justice Department announced the indictment in New York of Cary Yan, a Chinese entrepreneur, and Gina Zhou, his assistant, on FCPA and money laundering charges relating to a scheme to secure control of an atoll owned by the Republic of the Marshall Islands (RMI). Yan and Zhou paid bribes to elected officials in the RMI in exchange for passing specific legislation. Yan and Zhou...

General

31 Aug, 2022

SEC Modifies Whistleblower Regulations

The SEC has a long list of priorities and a full agenda. One issue on its list was to address changes needed to the SEC’s whistleblower program. The SEC’s whistleblower program has been a success. It was adopted as part of the Dodd-Frank Act in 2010. Since then, it has resulted in significant enforcement actions and large payouts to whistleblowers. Like any other program, the...

General

30 Aug, 2022

SEC’s Climate and Cyber Regulations Increase Compliance and Enforcement Risks (Part II of II)

You know companies face a new and aggressive enforcement regime when shorthand terms, such as “greenwashing,” are adopted prior to the implementation of comprehensive regulations governing disclosure of climate change issues and cyber-incidents. When these new regulations are adopted, companies will have to develop robust procedures for identifying potential violations of internal reporting and disclosure controls. This will be a difficult process. Along with the...