My good friend and colleague, Tom Fox, has written an interesting post (here) on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement theory is that United violated its Business Code of Ethics (and Continental’s Code of Ethics, which was in force in 2011 as well), resulting in the failure to...
Listen to the Corruption, Crime & Compliance Podcast
- What you don’t see is what you get: why governance matters May 13, 2022
- COSO ERM and Cloud Computing August 19, 2021
- Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship April 15, 2021
- Environmental, Social, and Governance or ESG April 14, 2021
- Internal Controls – A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately April 8, 2021