Podcasts
To implement an effective ethics and compliance program, global companies have to establish an effective internal investigation program. Whether conducting a critical or routine investigation, investigators have to be able to conduct interviews in a fair and effective manner. The success of an internal investigation often depends on the interviews
General
As a former federal prosecutor, I noticed a renewed discussion of the important question of whether witness interviews should be recorded (either audio or video). I have always found this issue to be interesting and have welcomed discussion of the pros and cons of recording witness interviews. In this era
General
A number of recent FCPA enforcement actions have cited common compliance program failures relating to internal investigations. For example, PTC settled FCPA charges with the DOJ and SEC for $28 million. According to the factual statements, PTC conducted three internal investigations focusing on alleged illegal payments to Chinese government officials
General
Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies have to “reinvent” compliance programs to incorporate new priorities and demands. Many companies have established complaint systems and internal investigation programs
General
Never argue with stupid people, they will drag you down to their level and then beat you with experience. – Mark Twain If only Mark Twain were alive today, he would have many opportunities to articulate his wisdom, especially when it comes to politicians. Not to say that the compliance field
General
Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations are valuable sources of information to improve compliance programs. Chief compliance officers play a critical role – either supervising the internal investigation system