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Imagination is more important than knowledge – Albert Einstein For companies trying to comply with the law, it is difficult to find quality attorneys to help. Forgive me for criticizing my profession but many of my colleagues take refuge in mechanical, non-creative thinking. To be a good lawyer and a
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Congress is setting its sights on the Justice Department’s enforcement of the FCPA. The business community has legitimate complaints which they have raised. The Justice Department is sticking to its guns and continuing to trumpet the importance of FCPA enforcement and the fairness of its enforcement program. The Justice
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It is amazing how professionals try and complicate tasks. The latest fad – “Enterprise Risk Management.” Corporations now have “Risk Officers.” Making ideas more complex does not mean more effective results. Overlapping corporate structures with multiple committees assigned to specific tasks are a compliance nightmare. It is really just a new
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If China is really number 78 in the Transparency International Corruption Perception Index rankings, I cannot even imagine the corruption conditions in the countries ranked 79 to 178. Russia stands at 154 out of 178. It should not surprise anyone that China and Russia are perceived as highly corrupt business
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The steady drumbeat of compliance continues – comply, comply and comply. The refrain goes even deeper – document, document, document. But can you imagine when the “rational” decision maker decides to continue engaging in bribery, or turning a blind eye to continuing bribery. Let’s examine a possible scenario. “Assume” (in the
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Much has been written about the Laura Stevens case. You will remember that she was in-house counsel for Glaxo Smith Kline and indicted for obstruction of justice and false statements for submitting an incomplete response to an FDA inquiry letter concerning off-label marketing tactics. The federal judge in
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The increase in FCPA enforcement has lead to the growth in the legal cottage industry surrounding compliance and enforcement. More and more companies are advertising their due diligence services, their intelligence gathering services, and their overall ability to help companies comply with the law. Lawyers are guilty of this mass
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Internal auditors are the compliance super heroes. But they are also the villains. Perhaps that is why they are frequently isolated or labeled as schizophrenics in any organization. The government wants to focus its investigations on internal auditors and hold them accountable as the gatekeepers, the people in a company
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Canada is an interesting country – not just to visit -- but in anti-corruption enforcement. Canada is dead last in the G7 when it comes to anti-corruption enforcement. Transparency International has consistently criticized Canada’s anti-corruption enforcement program as woeful. Last year, the OECD cited Canada for its poor
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“Quite as important as lawmaking is vigilant oversight of administration.” Woodrow Wilson, Congressional Government (1885) The scene on television is all too familiar. Corporate executives from a company in the headlines are dragged before a Congressional committee, they are placed under oath, and they are asked a series of questions