Jessica Sanderson, a Partner at The Volkov Law Group, re-joins us for a posting on her perspective on proactive compliance strategies. Jessica can be reached at [email protected]. I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle...
It is fun to follow all the early year views of trends, predictions and survey results. The beginning of the year includes lots of perspectives and analyses. Corporate boards are at the center of these important views. In a recent survey released by National Association of Corporate Directors, the top trends unsurprisingly referred to economic worries – inflation, a potential recession and continuing business disruptions....
There are a lot of so-called “dirty secrets” in the corporate governance world. Not the tawdry kind that appear to follow controversial politicians – I mean in the world of internal controls. I would wager that most companies cannot even identify all of the policies, procedures and controls that have been created during the life of the company. Some exist in what I call the...
Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles are a little less concrete; compliance controls are practical and focused on policies and procedures. A compliance program cannot be deemed effective, however, unless there is a combination of these two important functions. An...
A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does not violate the law. A much simpler way to put it is – a company’s due diligence system is designed to negate any inference of intent to violate the FCPA. A due diligence...
