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People love to make mountains out of mole hills. Or to put in another way (as my daughter might say), “She/he is a drama freak.” When it comes to structuring a compliance and ethics program, and the reporting lines, I have been accused of being a “drama freak,” meaning
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Forgive me for dedicating a posting to this topic, since I have a vested interest in this topic. I have conducted a number of Anti-Corruption Compliance Program Assessments. I am a strong advocate for conducting such assessments. My belief has nothing to do with compliance with the Sentencing Guidelines
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We all remember the fun we had as children playing hide-and-seek. It was a great game and those of us who are parents have passed on the rich tradition associated with that game. Unfortunately, in our kids’ world, I am sure it has been turned into an “RPG”
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My good friend and mentor, Judge Sporkin, is not shy nor bashful about his views on the FCPA. When he heard about DOJ’s undercover sting in the Shot Show case, he scoffed, “What a mistake! The government does not need to manufacture bribery. There is plenty going on and
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In 2010, Wall Street shuddered when it was disclosed that the SEC had launched an inquiry into financial institutions, investment banks and private equity firms for potential FCPA violations involving interactions with sovereign wealth funds. Since the initial press reports on the investigation, nothing has happened. DOJ’s recent criminal
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DOJ’s criminal enforcement of the FCPA was the story of the second quarter of 2013. DOJ’s splash was so big on criminal enforcement that it overshadowed DOJ and SEC’s continuing enforcement of the FCPA against corporations. Whether you favor or oppose DOJ and SEC’s use of
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Let me remind everyone about the FCPA doomsayers – those who were worried and fretted over the absence of FCPA enforcement actions in the first quarter of 2013. Remember the articles which wondered about the FCPA “slowdown” or whether DOJ prosecutors were gun shy after the Shot Show debacle. Well, DOJ
Events
Webinar - FCPA Compliance Programs: A Review of Best PracticesJuly 9, 201312 Noon - 1 PM ESTRegister: Here In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. As companies increase resources for compliance programs, it is important to stay abreast of industry best practices. Join Michael
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International enforcement of corruption laws is increasing but far slower than many predicted. As anti-corruption law enforcement increases, companies and individuals face the risk of a multi-jurisdictional nightmare: when a company has to pay fines in multiple jurisdictions for a single bribery scheme, or an individual may be
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The healthcare industry has a long history of innovative compliance policies and strategies. The government's role in the healthcare industry is going to grow even more after 2014, when a number of Obamacare provisions are triggered. For healthcare companies, regulation and enforcement will increase. The government's
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Italy is a popular destination for tourists and those seeking connection with their Italian roots. (I confess—I married a beautiful and wonderful woman from Sicily, so I am a little biased). Europeans love to travel to Italy during their lengthy vacations. Americans look for family connections while touring Italy
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After years of litigation and twists and turns, Mr. Bourke finally entered jail to serve his one year and one day sentence. Whatever you may think about the facts of the case, we can all agree on one thing – the result certainly would have been different if Mr. Bourke had