To restate the obvious – DOJ has prioritized prosecution of national security crimes.  For the business world, every company touches the international economy.  Even a domestic company might sell products or services outside the United States, or such companies depend on foreign products or services in their supply chain.  It is rare indeed to find a company that is not dependent on one way or...

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized based on resources.  Instead, these are essential and basic requirements that will inevitably result in significant benefits across the company.  Step 1: Define, Embed and Monitor Corporate Culture...

We are living in a rapidly changing economic landscape. Companies are under the gun to navigate “traditional issues,” such as challenging economic conditions ranging from inflation, and a predicted recession, to supply chain disruptions.  It has been a long and difficult path in responding to two significant crises – first the pandemic in 2020 and then Russia’s invasion of Ukraine and the resulting global sanctions...

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these situations, employee misconduct rates increase, wrongdoing and scandal surround the company, and corporate leaders ultimately fall from failing to sail the corporate ship in the right directions. There are tell-tale signs of...

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs. The story of corporate culture as a talismanic tool for ethics and compliance is really nothing new.  Chief compliance officers knew the importance of corporate culture from the beginning.  A number of companies separately called out...