Podcasts
Companies face a daunting challenge to reassure and regain trust and integrity with employees. CEOs should view the current situation as an opportunity to improve a company’s culture by building on the company’s trust and integrity values. Aside from basic economic questions, companies have to ensure that employee
General
Companies are under enormous stress given the pandemic and the social unrest. Employees are looking to companies to provide some sense of stability and ultimately leadership. Corporate leaders are being tested and it is clear that in this defining moment, some will rise and some will fail. It is pretty
General
The Novartis and Alcon FCPA enforcement action is chock full of interesting issues. See Novartis DPA Here , Alcon DPA Here and SEC Novartis Order Here. At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance
General
Novartis and Alcon engaged in separate but significant bribery schemes. Considering the fact that Novartis had a similar violation in 2016 in China involving much of the same conduct, Novartis’ conduct reflects a weak corporate culture of compliance. Novartis’ conduct is all the more troubling given its enforcement record on
General
Even during this difficult time of the pandemic, economic uncertainty and social unrest, the Justice Department and the SEC have concluded a major FCPA enforcement action. Novartis and Alcon (which was a Novartis subsidiary at the time of the misconduct) agreed to pay a total of $345 million in criminal
Podcasts
Even during this difficult time of the pandemic, economic uncertainty and social unrest, the Justice Department and the SEC have concluded a major FCPA enforcement action. Novartis and Alcon (which was a Novartis subsidiary at the time of the misconduct) agreed to pay a total of $345 million in criminal
General
Companies that rely on mergers and acquisition for growth have to build robust post-acquisition integration policies and controls. Such a requirement applies not only to ethics and compliance program integration but to overall business operations. Successful companies employ a robust pre-acquisition planning process, incorporating ethics and compliance as
General
The Justice Department’s recent revisions to the Evaluation of Corporate Compliance Programs highlights an important trend and evolution of prosecution focus. DOJ’s Revised Corporate Compliance Guidance recognized and reinforced the continuing focus on post-acquisition integration versus pre-acquisition due diligence. For years, DOJ and compliance professionals placed
General
After a lengthy sentencing hearing in federal court in San Francisco, Bumble Bee CEO Chris Lischewski was sentenced to 40 months in prison for his involvement in a tuna price-fixing conspiracy. The judge rejected prosecutors’ request to sentence Lischewski to 10 years in prison. Lischewski, who is 59 years
General
Several members of Congress have been implicated in potential insider trading scandals stemming from stock transactions that occurred at the beginning of COVID-19 crisis before the major stock market decline. As reported by the press, members of Congress were regularly being briefed on the implications of the spreading virus.
Podcasts
The Justice Department’s recent revisions to the Evaluation of Corporate Compliance Programs highlights an important trend and evolution of prosecution focus. DOJ’s Revised Corporate Compliance Guidance recognized and reinforced the continuing focus on post-acquisition integration versus pre-acquisition due diligence. For years, DOJ and compliance professionals placed
General
The Antitrust Division’s recent indictment of the boiler chicken executives provided an important reminder to compliance officers on the importance of an effective antitrust compliance program. With last year’s Guidance on Antitrust Compliance, DOJ has provided a roadmap for compliance officers to design and implement an effective compliance