This week I am posting a series on due diligence. Also, I just released a new e-book on due diligence which can be downloaded here. There are basically two types of people. People who accomplish things, and people who claim to have accomplished things. The first group is less crowded. – Mark Twain In a former life (or even present life), Mark Twain had to...
Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between getting a program implemented on paper and an “effective” anti-corruption compliance program. After all, when you boil it down, anti-corruption compliance is not as difficult a task as everyone thinks. Some programs are immature, some...
Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s illegal payments were intended to increase referrals by Chinese physicians and healthcare officials of Mead Johnson products, and obtain access to marketing and personal information about expectant and recent mothers. Over...
Date: August 6, 2015 Time: 2 pm – 335 EST Sign Up Here Many companies have implemented robust due diligence vetting, monitoring and auditing strategies for managing third-party risk. No due diligence system is foolproof in identifying high-risk business partners or predicting which partners will engage in bribery. Join Michael Volkov and Richard Bistrong as they discuss how due diligence systems and monitoring and...
It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not normally treat third-party payments as a high-risk activity. However, with increasing focus on illicit proceeds and tightening of AML/Terrorist Financing requirements, companies have to focus on this issue....
Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an anti-money laundering compliance program. My suggestion is not designed to promote business or even “scare” companies into addressing this issue – it makes sense...
We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...
