Events
Please join me and Tom Fox for a complimentary breakfast seminar on September 25, 2012 in San Diego, California. The seminar is being sponsored by Kreller Group. Anti-Corruption Due Diligence Workshop: Practical Steps to Protect Your Company from Third Party and Joint Venture Risks. When: September 25, 2012, 8
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With the Second Circuit’s recent reversal of the insider trading convictions in the Squawk Box case, United States v. Mahaffey, et al, (copy here), the trade press is ringing once again with claims of continuing prosecutorial abuse. Judging by press reports on this case and others, including the Senator
Events
I am happy to announce my pariticpation at several upcoming seminars sponsored by World Compliance. The next stop on the tour is Friday, August 17, 2012, in Bogota, Colombia. Here is a link to the event. I hope you can make it. After Bogota, we are scheduled to participate on
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I would like to welcome three new sponsors to Corruption Crime & Compliance. Each has unique capabilities in the compliance industry. Berkeley Research Group is one of the fastest growing and dynamic new consulting firms which provides forensic accounting, forensic investigation, strategic advisory and corporate intelligence services. BRG announced yesterday
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“Never argue with stupid people, they will drag you down to their level and then beat you with experience.” – Mark Twain Mark Twain’s quotes are timeless – his keen observations apply today just as they did years ago. A compliance program depends on rational decisions. Stupid decisions will undermine compliance.
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Corporate governance is the most important predictor of compliance. This may sound obvious but corporate boards move slowly. In many cases, corporate boards move way too slowly. Corporate failures usually rest on missteps and omissions by corporate leaders. It is a rare case for a company to have a board
Events
Join us for a Free Webinar: Health Care Fraud Enforcement Trends and Compliance August 22, 2012, at 12 to 1 pm SIGN UP HERE Health care providers, insurance companies and pharmaceutical and medical device companies face unprecedented risks of civil and criminal enforcement. The Justice Department's Health Care
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It would be interesting to study how companies respond to FCPA violations. A study on when all the dust settles -- after the company discloses FCPA violations, conducts an internal investigation, confirms improper payments, fires those employees responsible, settles with the government and pays a fine - would be particularly interesting. When
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The Justice Department always touts its FCPA, Criminal Antitrust and Health Care Fraud enforcement programs. It is very proud of its record in these areas. But quietly and methodically the Justice Department has ramped up, with little fanfare, its export control and sanctions enforcement program. For the first half of
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I have had more than one corporate general counsel tell me that anti-corruption compliance is not very effective in protecting against foreign bribery. Their argument is that a company’s compliance program boils down to the behavior of individual employees. An employee will either decide to violate the law
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The SEC is not a shrinking violet. When it comes to FCPA enforcement, some focus more on the Justice Department – and given its criminal enforcement mission that is understandable. But the SEC has a strong enforcement role to play, and in the last year or so, it has been flexing
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A recent survey found that close to half of all responding companies had established or increased anti-corruption compliance. That is a very positive response to increased FCPA enforcement. It is time and money well spent. Increased compliance reduces risk. Companies have to be realistic about the enforcement risks. Most