Invoice to payment process Archives - Corruption, Crime & Compliance

20 Feb, 2019

Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV)

The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post. Putting those concerns aside, there are some important lessons learned and observations that should be examined. Credit for Pre-Existing Compliance Program: From a compliance perspective, DOJ’s declination letter explicitly credits Cognizant’s compliance program, citing “the existence and effectiveness of the Company’s pre-existing compliance program,...

A Basic Compliance Requirement: A Contract Management System

General

9 Oct, 2018

A Basic Compliance Requirement: A Contract Management System

Assume you are under the influence of a truth serum; does you company have a contract management system? Some will say yes; I suspect most will say no. My question is why not? Lawyers love contracts. Most business people see the value of a contract and will comply with a requirement that a deal will require a contract in order to move forward. But there...

Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II)

General

8 May, 2018

Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II)

The Panasonic Avionics (PAC) FCPA enforcement settlement for $280 million with the Justice Department and the Securities and Exchange Commission contains a number of important lessons learned. The overall scope and breadth of PAC’s misconduct was significant and reflects the absence of a meaningful compliance program and commitment to a culture of ethics. Here are the important lessons learned: C-Suite Misconduct: PAC is yet another...