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
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
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
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
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
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
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
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,
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,
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
