It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors. There are common factual scenarios that recur in DOJ and regulatory enforcement actions, some of which fall into certain categories. While defense counsel (being effective advocates) often argue that bad actors are often “rogue” employees,...
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- COSO ERM and Cloud Computing August 19, 2021
- Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship April 15, 2021
- Environmental, Social, and Governance or ESG April 14, 2021
- Internal Controls – A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately April 8, 2021
- Ethics and Compliance: Active Board Involvement Is a Must April 5, 2021