When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and violates the FCPA. This was a
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years
One of the key changes coming out of the Covid-19 pandemic is the need for dynamism on corporate policies. This message was driven home in
More than simply having a Code of Conduct, compliance policies and procedures are required. As former Assistant Attorney General Lanny Breuer articulated, “Your compliance program
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
How can you work to operationalize your Code of Conduct as articulated in the DOJ 2023 Evaluation of Corporate Compliance Programs (ECCP)? The 2023 ECCP
What about the training on your finalized Code of Conduct? While there have been criticisms of code training, if you consider training as one source
Next comes the evolution of the structure and format of a best practices Code of Conduct. Initially, my experience with this is that they were
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
The written standard requirements have long been memorialized in the U.S. Sentencing Guidelines, which contain seven basic compliance elements that can be tailored to fit
