Uncategorized
The headlines are dominated by FCPA, Roger Clemens and John Edwards. AML enforcement has come back to business attention. There has been a lot of news around the subject of Anti-Money Laundering (AML) laws and the Bank Secrecy Act (BSA) recently. The Office of the Comptroller of the Currency
Uncategorized
It is amusing to listen to companies complain about the burdens of anti-corruption compliance. It is hard to sympathize when you consider the burdens on other industries, particularly the health care industry. If the Chamber of Commerce only knew how burdensome and difficult health care regulations can be, they
Uncategorized
Companies complain about the burdens of anti-corruption compliance. They need to put things in perspective. The “greatest” risk of them all may be the False Claims Act (FCA). FCA violations can lead to severe consequences, especially for government contractors. Since the FCA was amended in 1986, more than $30
Uncategorized
In the end, what was more pathetic – the government’s prosecution of John Edwards or John Edwards himself? I hate to say it but both sides came out the losers. John Edwards needs to crawl back under the rock from where he came. The sooner the better. His post-trial
Uncategorized
Chief compliance officers have enough on their plate without having to worry about another risk. The Obama Administration came into power promising to increase enforcement of environmental laws and regulations. On the civil and regulatory side, they have done that and more. The EPA has been aggressive and increased civil
Uncategorized
Can you imagine the discussions inside Target, The Gap, Levi’s and other global retailers the day after the New York Times story broke? I would love to have been an observer of meetings and conversations among top brass at these companies. Global retailers must be suffering from sleepless nights.
Uncategorized
Patrick Kellermann (a regular contributor) and Tom Cohn, both from LeClair Ryan, are guest contributors today and provide an important posting on data privacy, a fast growing and important issue which creates significant risks for all businesses. Patrick and Tom can be reached here and here, respectively. This post, the
Uncategorized
FCPA bloggers can be repetitive. We like to repeat important points. How many more times do we have to remind everyone on the importance of documentation?In the interest of originality, I wanted to address documentation for a due diligence package of third-party agents. Every FCPA enforcement case involves
Uncategorized
My wife, Rosetta, and I have collaborated on this post in honor of Memorial Day. Rosetta, writes a regular blog on Sicily Cuisine Culture and Tradition -- the link is here. I have lived in Washington DC all of my life. It is a majestic city, filled with memorials and history.
Uncategorized
Patrick Kellermann from LeClair Ryan is our guest contributor today. He can be reached here. For many businesses, now is the time to expand into Russia. In 2011, the Russian economy grew by 4.3%. The IMF projects the $1.8 billion economy will continue to grow by 3.3%
Uncategorized
In the compliance world, lawyers and accountants are strange bedfellows. Sometimes they need each other, and sometimes they do not. Each has advantages and disadvantages. Working together, you get both. I shudder when I think of companies that have hired accounting firms to conduct internal investigations, design compliance programs, or
Uncategorized
The Middle East is a diverse area with significant disparities in the region. Oil and gas dominate the economies. Cultural and economic factors make compliance extremely difficult in the Middle East. Interestingly, on the Transparency Index, a number of Middle East countries fall above the median (e.g. Qatar 22,