In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the new blog post on my colleague Tom Fox’s excellent blog (here) or Matt Ellis’ excellent blog (here), or many...
When the going gets tough, the tough do not necessarily get going. This is evident in the world of corporate governance, compliance, and defense against aggressive government enforcement. Corporate lobbying interests are pushing a new and dangerous agenda, one that is shortsighted and certain to create problems for chief compliance officers. Several years ago the Chamber of Commerce launched an attack on FCPA enforcement with...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about third-party due diligence. Lauren’s profile is here, and she can be reached at [email protected]. Most discussions of third party due diligence begin with an explanation of indirect liability and the “deliberate ignorance” standard of knowledge the FCPA imposes. With so much focus on anti-bribery it is easy to lose...
As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges. Compliance is a fast moving profession. More attention is being paid to the compliance function, and more companies are embracing the importance...
Webinar: Anti-Corruption Enforcement and Compliance — The Year in Review January 5, 2016, 12 noon EST Sign Up Here The past year — 2015 — was another eventful year in global anti-corruption enforcement. While the US Department of Justice enforcement activity slowed, the SEC and other governments increased enforcement activity. DOJ’s enforcement program took some unusual twists with the hiring of a Compliance Counsel and...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about self-reporting FCPA violations. Lauren’s profile is here, and she can be reached at [email protected]. One of the critical questions when evaluating a potential FCPA violation is to decide whether to disclose the matter to the Justice Department and the SEC. The SEC recently announced a requirement for companies to voluntarily disclose...
The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU (video here), Andrew Weissmann, the head of the Fraud Section, and Ms. Chen spoke about the new compliance position. The video provides important information. Ms. Chen...
Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these essential partners – senior leadership and key compliance functions. In a company culture, teamwork...
Free Webinar: DOJ Shifts Prosecution Strategy December 15, 2015, 12 Noon EST Sign Up Here I am pleased to announce that Tom Fox, Principal, Advanced Compliance Solutions, and I are conducting a joint webinar on Tuesday, December 15, 2015 at 12 pm EST, on the Justice Department’s shifting FCPA prosecution strategy and compliance program requirements. The Justice Department’s FCPA enforcement program is expected to undergo...
Do the right thing. It will gratify some people and astonish the rest. – Mark Twain We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who stands up and speaks about the company’s culture of compliance is more than a breath of fresh air – it can be the lifeblood...
