General
The Justice Department and the Securities and Exchange Commission have dedicated more time and energy to understanding a company’s internal controls and enforcing basic requirements that companies maintain effective internal controls. For prosecutors, companies often fall short when it comes to following their internal controls. If you follow my
General
In the technology age in which we live, CCOs often come face to face with a new phenomenon – too much information or data. TMI is not something to laugh at nor ignore. CCOs often face situations where they need to understand what is occurring through a monitoring or audit function.
General
The importance of DOJ’s hiring of Hui Chen as Compliance Counsel was recently confirmed by DOJ’s release of new compliance remediation standards for FCPA compliance programs. DOJ has, once again, raised the bar on FCPA compliance programs. Compliance practitioners have a real and significant voice on behalf of
General
Happy April Fool’s Day! Could you ever imagine coming to work one day and realizing that you have “finished” your ethics and compliance program? There is nothing left to do. You can go home. Ohhhh, if only it was so. We all know the truth – a compliance program is