Tagged: C-Suite risk assessment

J&F Investimentos FCPA Settlement: Lessons Learned (Part IV of V)

J&F Investimentos (“J&F”) FCPA settlement presents a number of important lessons learned.  While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly obvious.  Despite J&F’s large global operations and expansion plans, J&F made no apparent effort to build an ethics and compliance program or implement basic compliance requirements, such as a Code of...

CCOs and the C-Suite

Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance. Unfortunately, when a member or members of the C-Suite commit misconduct, the consequences can be devastating for the company. We all know high-profile instances of C-Suite misconduct involving bribery, fraud, and theft....