Tagged: Gifts and Entertainment Expenses

Compliance Messaging: Need a Reason? ‘Tis the Season!

Jessica Sanderson, Of Counsel at The Volkov Law Group, rejoins us for a posting on gift-giving, the holiday season and compliance messaging. Jessica can be reached at jsanderson@volkovlaw.com. As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy. DOJ Guidance highlights tailored communications as a “hallmark” of any well-designed compliance program, and...

United Technologies SEC FCPA Enforcement Action: Gifts, Meals, Entertainment and Travel Abuse and Bribery (Part II of II)

When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator is disturbing. As outlined in the SEC settlement, from 2009 to 2015, Pratt & Whitney and Otis Elevator improperly provided trips and gifts to various foreign...