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It has been ten years since Sarbanes-Oxley was enacted. No one can argue that Sarbanes-Oxley eliminated the problem of corporate malfeasance. Maybe Sarbanes-Oxley did not address the real problem. Corporate scandals occur when corporate governance fails to properly supervise corporate operations. Senior management may try to keep
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No one will ever call the last twenty years of television the “golden age of television.” I have always turned off “reality” television for one reason – it is boring. For some reason, American television viewers have become less interested in entertainment and more interested in watching so-called “reality” shows
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The FCPA Guidance contains many important compliance reminders which should be incorporated into every anti-corruption compliance program. Perhaps the most important observation included in the FCPA Guidance was the statement that: DOJ and SEC have often encountered companies with compliance programs that are strong on paper but that nevertheless
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We can all agree on one thing – Lance Armstrong is a disgrace. I have never seen a more pathetic performance of contrition, riddled with lies, and confirmation of a true sociopath. His public relations strategy was a disaster. It is hard to know who to blame but perhaps it was
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To restate the obvious, hospitals operate in a risky environment. They face a variety of risks and a blanket of government regulations. You have to admire the Chief Compliance Officer at a hospital. They learn to live with these risks. In response to our new Internet age, the government has
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The FCPA world is fast-becoming the leader in new compliance strategies. The Justice Department and the SEC have embraced the requirement for conducting “proactive audits.” Recent settlements have included new compliance program requirements for a company to conduct proactive audits of high-risk areas. It is a new and
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It is hard to know whether the government’s aggressive enforcement of insider trading laws deters criminals from violating securities laws. One key factor in this equation is the risk of getting caught. The Obama Administration can certainly point to an increase in enforcement – civil and criminal. Judges have been
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Many people ask “Why do I need a lawyer?” Candidly, sometimes it is hard to answer that question. (I often ask myself the same question). On a more “sophomoric” note, I often think of the attorney-client privilege as the “cone of silence” often used by Agent 86, Maxwell Smart,
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I always like to make predictions at the beginning of each year. My track record is plus and minus – sometimes on target, sometimes off-target. The biggest story in the last five years has been the rise of FCPA enforcement. That story was eclipsed last year by the LIBOR scandal,
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Healthcare suppliers and service providers live in a regulated world. They are constantly under audit scrutiny. Sometimes federal agencies (i.e private contractors) conduct the audits; other times state agencies conduct the audits. The audits also vary in focus – claims, coding, privacy, and compliance. The industry is constantly being audited.
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I am happy to welcome back Tom Echikson, a partner in LeClairRyan's Environmental Practice. Tom's bio is Here. Shortly before the end of the year, EPA released its annual review of its civil and criminal enforcement results for the Fiscal Year 2012. See Here. Touting massive