Podcasts
The Justice Department and the Securities and Exchange Commission had another strong year in FCPA enforcement. The numbers for 2018 tell a compelling story. CorporationsIndividualsDeclinationsFines/PenaltiesDOJ 5 26 4$950 millionSEC 14 4 NA$380 millionTotal 19 30 4$1.33 billion In this episode, Michael Volkov reviews FCPA enforcement
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Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a mature ethics and compliance program is whether the company assesses and mitigates its
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Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions against a high-risk industry. Whatever the enforcement background, Sanofi settled an FCPA case with the
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Laws control the lesser man --- right conduct controls the greater one – Mark Twain A company’s internal controls define the backbone of its operations, encompassing financial, operational and compliance functions. The FCPA defines requirements for publicly-traded companies to implement internal controls, including compliance controls. Under the internal controls requirements,
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With the close of 2017, FCPA enforcement continues as a major priority for the US Department of Justice. Notwithstanding fears and concerns that the new administration would turn its back on FCPA enforcement, the Justice Department’s work continues unabated and unhindered. All the doomsayers have to admit that no
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No matter what, I am an optimist. A pessimist’s worldview and lifestyle is really unattractive. I would always rather see the glass as half full. Too many in the professional world have confused negative perspectives and predictions as a way to demonstrate their own expertise. It is an unfortunate
Events
Rescheduled Webinar: Rising Government Expectations for Compliance Programs November 10, 2016, 1 PM EST Sign Up HereMy apologies but I had to reschedule the webinar: Rising Government Expectations for Compliance Programs to November 10, 2016, 1 PM EST. The Justice Department has made it clear that companies have to design
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Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines for the year so far, and I suspect more to come as we get
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Analogic Corp. and its Danish subsidiary, BK Medical ApS, settled an FCPA enforcement action last week with the Justice Department and the SEC for approximately $14 million. Analogic agreed to pay $3.4 million to the Justice Department as part of a non-prosecution agreement (NPA), and paid the SEC
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A number of companies have adopted the requirement that a new Chief Compliance Office come from the ranks of former federal prosecutors. I am not sure exactly why companies have adopted this requirement. Perhaps company leaders think this will give the company an advantage when dealing with the Justice Department
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Maybe I am a Luddite; maybe I just do not understand the new world and the impact of globalization. New ideas do not scare me, like others we know. New ideas present real opportunities for progress and innovation. I understand the impact that globalization has had on our economy, our
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With increasing focus on infrastructure projects and greater public demand for improvements, governments are preparing to ramp up construction projects. Part of the budgeting process has to acknowledge the cost of corruption. It does not take a rocket scientist to figure out that construction and corruption go hand-in-hand.