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Compliance programs depend on accurate and timely information. AML compliance centers on sifting through thousands of transactions and matching them against risk profiles. The result of that process is a focused examination of transactions and identification of suspicious transactions. Financial institutions have to create a customer risk profile against which
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I often use sarcasm to make the point that compliance solutions are just a profound grasp of the obvious. It is a little simplistic. On the other hand, compliance can become a little too complex. People like to come up with “sophisticated” techniques and phraseology to demonstrate they are “compliance
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When I was growing up (and probably for generations), every proud parent wanted their son or daughter to go to medical school. With the increasing role of government in healthcare and the changing economics, the profession has lost a bit of its luster. Federal prosecutors are creative when it comes
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Pharmaceutical and medical device companies have enough to worry about when it comes to enforcement risks. It is only in the last ten years that FCPA enforcement has been added to their list of worries. With the increase in FCPA enforcement, pharmaceutical and medical device companies have to worry about
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One of my favorite Seinfeld episodes is “The Opposite” when George decides to do the opposite of his natural inclination, and lo and behold, his life suddenly improves. There are days when we all feel like George Costanza. Compliance professionals and lawyers apply this same principle to FCPA criminal liability.
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I am happy to welcome a new sponsor to Corruption, Crime & Compliance – The Network. (You will see its sponsorship ad on the right hand side of the blog). I am always happy to affiliate with professionals in the compliance industry. The Network has been the leader for over 30
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Kazakhstan is the most economically prosperous of the former Soviet Republics. Along with economic growth, however, has come significant corruption. Much of Kazakhstan’s growth has been due to its vast supply of natural resources, especially oil. The Kazakhstan government has kept tight control of the oil supply and government
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Companies which fall under the enforcement axe usually learn from their mistakes. All it takes for most companies is the scrutiny of the federal government and then companies react with the motto – “never again!” But what happens if such change does not occur, or for some reason, you company is
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AML compliance is filled with fascinating issues, lots of acronyms, and plenty of common sense. One of my favorite areas is KYC (which I originally thought stood for KFC – Kentucky Fried Chicken), or Know Your Customer. KYC is a critical area for every financial institution. Due diligence kicks in depending
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Sometimes what we think is obvious is really not so obvious. Sometimes bold conclusions mask nuances or difficult issues. To my surprise, the economic literature surrounding the impact of corruption on economic development is not as clear-cut as everyone thinks. No one argues that corruption is good for a
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Pharmaceutical and medical device companies have a raw deal when it comes to domestic and foreign bribery. On the domestic front, they have to comply with the Anti-Kickback and Stark laws. In the international sphere, they have to worry about the FCPA. They are heavily regulated in the US
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We have a guest post today from Jim Boeckman, focusing on compliance lessons from the recent Tiger Woods rule controversy. Jim is a business lawyer in Austin, Texas, who works with small and mid-sized companies, and can be reached at Jim@BoeckmanLaw.com. With the 113th U.S. Open