Corruption, Crime & Compliance

Featured Articles:

24 Aug, 2021

Pipeline Company Pays $35 Million to Settle Criminal and Civil Environmental Violations for Inland Spill of Oil Drilling Generated Water

In a significant environmental crime enforcement action, the Justice Department resolved criminal charges under the Clean Water Act against Summit Midstream Partners LLC, a North Dakota pipeline company that discharged 29 million gallons of water of produced water from its pipeline near Williston, North Dakota. In addition to the criminal resolution, the United States and the States of North Dakota resolved civil charges against Summit...

General

24 Aug, 2021

The Dangers of a Fractured C-Suite

All for one and one for all – The Three Musketeers motto – Alexander Dumas We all know the importance of teamwork and collaboration. Whatever the context, sports, business, military, and many other situations, teamwork and cooperation is essential to success. Our political system, however, is not a model for cooperation or bipartisanship. In the face of these tensions, it becomes harder to maintain a...

General

23 Aug, 2021

5 Common Internal Investigation Pitfalls

An internal investigation is like reading a good novel. You begin the journey with a general expectation of what the novel or the “investigation” is about. As every reader knows, the exhilaration is the result of following an unexpected path filled with moments of discovery, surprise and ultimately a basis for understanding. Internal investigations can follow a similar path. In some cases, the end of...

Podcasts

22 Aug, 2021

Episode 204 — “This is the Way” on Corporate Culture

The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations. In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s “culture of compliance.” But when it comes to defining the terms, how to...

General

19 Aug, 2021

SEC Approves Nasdaq Board Diversity Proposal

The growing demand for increased diversity on corporate boards passed another hurdle. The SEC approved to Nasdaq’s proposed rule changes to mandate increased board diversity requirements. Three SEC Commissioners, including Chairman Gensler, approved the measure, and one Republican commissioner opposed the measure. The other Republican commissioner supported the proposal only in part. Under the new Nasdaq rules, listed companies would have to meet minimum targets...

General

18 Aug, 2021

Remediating the Organization’s Culture (Part IV of IV)

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) This straight-forward statement (above) of a company’s commitment to its “effective” compliance program is powerful. In a nutshell, it says it all. Over the years as a federal prosecutor, and later as outside counsel, I have witnessed a variety of responses to misconduct. On the one...

General

18 Aug, 2021

Measuring and Reporting on the Organization’s Culture (Part III of IV)

While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures. Let’s start with a simple proposition – if a company’s culture is its most important internal control and its most valuable intangible asset, a chief compliance officer (CCO) should devote commensurate time and energy to promote...

General

16 Aug, 2021

Practical Approaches to Managing Culture: Defining the Organization’s Mission (Part I of IV)

The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations. In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies, continue to cite the importance of a company’s “culture of compliance.” But when it comes to defining the terms, how to...

Podcasts

15 Aug, 2021

Episode 203 — Interview of David Greenberg on LRN’s Report on Corporate Boards and Compliance Program Engagement

LRN recently issued its second of three annual reports on ethics and compliance program effectiveness. The second report focuses on board engagement with ethics and compliance and lessons learned from the COVID-19 pandemic. David Greenberg, a Special Advisor to LRN, joins us to discuss the interesting results of the LRN report. The LRN report can be downloaded HERE.