Over the past decade, the increase in global anti-corruption enforcement has profoundly impacted large, multinational corporations. Many of these companies have responded to the enforcement increase by investing heavily in sophisticated compliance programs designed to prevent or mitigate liability for anti-corruption violations.… Continue Reading
Imagine your house is on fire. In the front of the house, you have a fire department working tirelessly to put out the fire with water. In the back, someone is spraying your house with gasoline.*… Continue Reading
I recently read a Wall Street Journal article which discussed a $4.5 million award issued by the SEC to a whistleblower. The agency granted the award pursuant to a rule designed to incentivize internal reporting by whistleblowers who also report to the SEC within 120 days.… Continue Reading
The FCPA Blog’s post Wednesday about important cases mentioned Telia, Siemens, TSKJ, The Africa Sting, and U.S. v. Kay. For the reasons set out in the post, those are all good candidates.… Continue Reading
The nation collectively gasped last week when the media reported that the IRS awarded Equifax a $7.25 million sole source contract to “verify taxpayer identities and help prevent fraud.”
Yes, that Equifax.… Continue Reading
It’s a phrase every compliance officer or compliance consultant is familiar with: “This is how we have always done it.”
Readers — you know what I’m referring to. You try to implement new policies or provide guidance regarding compliance best practices and some pushback is always inevitable (I am looking at you, sales team!).… Continue Reading
The DOJ’s Yates Memo is nearly a year old. The anti-corruption and compliance communities are still wondering what impact it will have on individual responsibility for white collar crimes. That in turn has brought more interest about past prison sentences for FCPA offenses and what future defendants might expect when sentenced.… Continue Reading
Last week, the U.S. Interagency Suspension & Debarment Committee (ISDC) released its FY2015 report. The annual report to Congress describes the status of the U.S. suspension and debarment system.
While the full report is informative, I found one area to be particularly illuminating: its discussion of appropriate metrics and agencies’ expanding use of diverse suspension & debarment tools.… Continue Reading
In January, CBS’s 60 Minutes aired Anonymous, Inc. in which a person with Global Witness, pretending to be a lawyer representing a minister from a poor West African country, sought legal advice about investing millions of dollars into the United States.… Continue Reading
Last week, the U.S. Department of Veteran Affairs (VA) proposed a new verification process to help combat small business fraud.
The government uses its procurement policies to further socio-economic goals, such as contracting programs for certain groups, including socially disadvantaged individuals, service-disabled veterans and women.… Continue Reading
Several weeks ago, the Society of Corporate Compliance & Ethics (SCCE) hosted its annual Compliance & Integrity Institute in Las Vegas.
Every year, at a special awards dinner (held during the conference), the SCCE honors the important contributions that various individuals, companies and media outlets have made to the field of ethics and compliance.… Continue Reading