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We always read that corporate leaders regularly identify data security as one of the top-five risks they face in the business world. Many companies are appointing a Chief Privacy Officer to oversee the proper handling of data. In some cases, Chief Compliance Officers are charged with responsibility for protecting
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Whenever a new competitor threatens an established industry, you can always count on entrenched competitors to use any strategy they can to frustrate the new competing technology. Our economic history is replete with examples of this phenomena. The virtual currency industry, which is rapidly growing, is a threat to traditional
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It is almost a government rite of passage – when a new leader takes the reins, the chessboard has to be reorganized to reflect the new leader’s “new priorities.” When it comes to the SEC, and the new Chairwoman Mary Jo White, the “new priority” is the return to an
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In a fitting tribute to the departing Deputy Assistant Attorney General Scott Hammond, the architect of the Antitrust Division’s criminal enforcement plan, the Department of Justice last week announced a record criminal settlement in its largest criminal investigation ever – the auto parts investigation. Nine Japanese companies and two executives
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I would like to think of myself as an advocate for the Chief Compliance Officer. It is easy to see why the CCO and the General Counsel should be separate individuals but close colleagues who depend on each other. Separation and dependence is a hard act to put together in
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The privilege to serve on a corporate board is no longer the cushy experience of our forefathers. The increase in enforcement actions has led to a dramatic change in the role – and the risks – facing corporate boards. Companies dread hearing lawyers recommend the need for an internal investigation. Alarm bells
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The growth of the compliance industry has included an increase in business surveys and specific attitudes towards corruption and compliance programs. They are interesting to read, not as the definitive source of business compliance trends, but as one of several pieces in the compliance puzzle. I try to follow most
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The Antitrust Division and practitioners live in their own world. It is part of the fabric when you work in the Antitrust Division – it is an entity unto itself within the Department of Justice. For years, the Antitrust Division has been able to fend off greater control by the DOJ
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You never see the words “poor” and “JP Morgan” in the same sentence. It is a historical oxymoron – the words do not fit together. However, if you have been following the headlines lately – you have to think to yourself, “poor JP Morgan.” How can a company get hit so hard,
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The latest hub-bub about hiring of relatives of foreign officials under the FCPA has raised a number of interesting questions. JP Morgan’s recent disclosure of its hiring practices, the existence of a list of such hires which are apparently tied to foreign government contracts, raise serious questions about
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The internal corporate world mimics broader social forces. A perfect example of this is a corporate disciplinary system and our criminal justice system. The analogy works like this – if justice is handed out in a disparate way, meaning that similarly situated individuals who commit the same offense are treated differently
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Hospitals are being squeezed on many fronts – government reimbursement for medical services are declining, government regulatory requirements are increasing, and the prospects for improvement are dwindling. Medicare and Medicaid payments come with so many restrictions and conditions that healthcare providers, including hospitals, face serious business calculations on whether or not