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Everyone claims to know how to conduct an internal investigation. Given the government’s reliance on internal investigations, law firms have beefed up their internal investigation services. Inevitably, the quality of internal investigations will be mixed. Internal investigations can cost lots of money, especially when conducting a global investigation. Avon
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China’s entry into the anti-corruption enforcement arena has received lots of press attention. Just as significant as this development, China has added international cartel enforcement to its list of priorities. With far less fanfare, China has found “religion” when it comes to prosecuting price fixing conduct. China’s
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Companies implementing due diligence programs face a number of challenges. It is hard enough to identify all of a company’s third-party intermediaries – agents, distributors, customs and logistics representatives, nominees, and professionals, just to name a few. Getting your arms around these third parties to make sure they are
General
The GM debacle over its handling of the ignition switch defect continues. GM’s CEO Mary Barra and the rest of GM’s leadership just do not seem to be getting the message. It is not unusual for C-Suite executives to lead from an ivory tower. In the face
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Chief Compliance Officers who lament the challenges of their jobs should be thankful they are not in charge of compliance for higher education institutions. The culture of compliance has extended into many high-risk areas but one area where compliance is catching up is higher education. Universities and colleges face
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The Justice Department recently read through the United States Code and discovered something important -- a statute that authorizes the government to issue administrative subpoenas to build massive civil fraud cases that carry huge penalties. For some reason, the Justice Department never used the statute until recently as a weapon against
Webinars
In today's aggressive enforcement environment, the importance of internal investigations has increased. Companies have to ensure that they maintain effective internal investigations protocols. In situations where outside counsel are needed, it is critical to ensure that outside counsel adheres to important practices and procedures needed to protect the
General
The Justice Department has a penchant for disclosure – they tell you what they are going to do in advance and then they do it. Companies have tried to claim they were “shocked” or “surprised” by the Justice Department’s actions but their claims have a hollow ring to them. For
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Many companies do not realize the importance of creating a “Speak Up” culture and how to deal with whistleblowers. Too many companies say they want to hear about problems but when employees raise the issues they become defensive. This is particularly true when dealing with whistleblowers. The natural response to
Events
Webinar: Tuesday, October 28, 2014, 12 Noon ESTAnti-Corruption Compliance for Small and Mid-Sized CompaniesSign Up Here Global companies are implementing anti-corruption policies and procedures. Many of these companies have an "abundance" of resources in comparison to small and mid-sized companies. For non-Fortune 500
Webinars
Companies are implementing due diligence programs to screen and monitor third party intermediaries. In doing so, companies are considering cutting edge techniques and technologies to improve the detection and prevention of fraud, bribery and other misconduct. At the same time, companies need to employ creative problem-solving techniques to protect
General
Chief Compliance Officers have to recognize one immutable fact – if a company does not make money, compliance does not matter. I know this is hard to fathom but a company’s purpose is to make money. The issue boils down to an important question – how does the company want to