The year in Foreign Corrupt Practices Act (FCPA) enforcement started off with a bang on January 10 with the announcement of a resolution of the outstanding SAP enforcement action. The…
The year in Foreign Corrupt Practices Act (FCPA) enforcement started off with a bang on January 10 with the announcement of a resolution of the outstanding SAP enforcement action. The…
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law such as Sarbanes-Oxley (SOX). Cristina…
What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as: An internal control is an action or…
There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2023…
What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during…
Mike Volkov, in a blog post entitled, Mood in the Middle Versus Tone at the Top, said, “Even when a company does all the right things at the senior management…
The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to…
Matt Galvin, Counsel, Compliance & Data Analytics at the DOJ and one of the experts leading the DOJ’s data analytics initiative, highlighted in another talk, the proactive use of data…
We continue our review of DOJ initiatives from 2023 and what they may portend for the compliance professional in 2024 and beyond. In October 2023, Deputy Attorney General Lisa Monaco…
Assistant Attorney General Kenneth A. Polite, Jr. began his speech with an interesting aside. It is about the clear tie between poverty and corruption. This is why it is important…
