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Patrick Kellerman from LeClairRyan returns with a blog posting on data privacy and data security. His profile is here.If you ask in-house counsel what keeps them up at night, the response invariably includes “data privacy and security.” It is a cutting-edge compliance and enforcement risk. As with
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I know I am not supposed to say this but compliance can be simple. That sounds like heresy but it is not. A person’s intelligence is always reflected in their ability to explain complex topics in simple terms. You may be the smartest person, the greatest thinker of all
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I am honored to welcome back Donna Boehme for today's posting. Donna is an internationally recognized authority and practitioner in the field of organizational compliance and ethics, designing and managing compliance and ethics solutions within the U.S. and worldwide. As principal of Compliance Strategists LLC, Donna is
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Companies discover FCPA violations all the time – most are small and few are big. Most companies learn of these violations when implementing or upgrading their compliance program. Typically, FCPA violations are discovered in the aftermath of an acquisition (months or even years after the acquisition), or in a company’s
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The financial recoveries for healthcare fraud are staggering. The Justice Department and Health and Human Services (Office of Inspector General (“OIG”) and Centers for Medicare and Medicaid Services (“CMS”)) regularly trumpet another round of healthcare fraud arrests and prosecutions. They have turned healthcare fraud prosecutions into a cottage industry with
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Benchmarking is a valuable tool because it gives you a window into industry practices. Compliance professionals have to be careful how they use benchmarking information. Falling into a benchmark should not necessarily give someone comfort. It is better to develop your own “personal” benchmark – what you think the company needs,
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The old English proverb, “You can lead a horse to water but you can’t make it drink,” is particularly apt when you think of the financial industry and corruption compliance. Maybe it comes from compliance overload, or maybe it is something else in the DNA of the financial industry.
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I recently had the pleasure of meeting with the compliance staff of a major global company to discuss issues of concern and share ideas. It was not only a productive meeting; it was an exhilarating experience.You can always learn a lot from compliance professionals – they live and breathe the
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The FCPA Paparazzi has done a great disservice to the business community. Call it a complete lack of credibility. Legal marketing has become confused in this day and age – marketing has now been turned into the “Fear Factor,” meaning that lawyers need to scare potential clients into hiring them. That
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For your weekend pleasure, I wanted to share with you my wife, Rosetta's blog: Sicily: Cuisine, Culture & Tradition. Please check it out and bookmark it for future reference. Sicily is a magical island with fantastic beaches, food, wines, and wonderful people. I urge everyone to travel and
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Every company knows that its internal auditing function is the lifeblood of its compliance program. Some companies carry that to an extreme by placing the overall compliance function in the auditing department. As we all know, that is a mistake.Auditing plays a critical role in every compliance program. Why?
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The Consumer Financial Protection Bureau continues to throw its weight around. The CFPB is not shy nor is it reluctant to take on some of the biggest financial players in the industry. The CFPB is still expanding its reach and its intended targets for investigation and prosecution.Recently, the CFPB