I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends.  It is a perspective that gives us all the opportunity  to identify important trends and to set an agenda for the next year – 2023. The compliance profession continues to grow in overall importance in the corporate governance landscape. Corporate leaders that fail to appreciate this face...

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...

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....