With the U.S. government encouraging businesses to earn cooperation credit at the penalty phase of enforcement actions through the “naming of names” at the onset
We’ve seen in the past few years more CEOs stepping down for displays of poor conduct, bad judgment, and even a disregard for taking misconduct seriously enough. Travis Kalanick at Uber, Roger Ailes at Fox News, Dov Charney at American Apparel, and Harvey Weinstein at The Weinstein Company are among them.
In writing and speaking about regulatory compliance, one term that comes up quite a bit is “credible deterrence.” When deterrence is real, institutions and the people in them are able to resist any temptation to skirt legal and regulatory imperatives, if only because of the fear of likely repercussions.
The streak of expense-claim abuses that reportedly caused some 200 employees to lose their jobs at Fidelity Investments may be familiar to the many firms that offer partial reimbursement for expenses such as computers and accessories or fitness memberships and equipment.
Former Telia Compliance Chief Michaela AhlbergMichaela Ahlberg created a compliance program from scratch when she was hired in 2013 by Swedish telecommunications firm Telia following allegations of corruption in its foreign business dealings.
Cravath partner David M. Stuart I recently spoke with David M. Stuart, one of the attorneys who represented Telia Company AB, a Sweden-based telecommunications provider that settled violations in September for a grand total of $965 million in financial sanctions.
Last week I spoke with Philip Urofsky, a partner at Shearman and Sterling, and a former federal prosecutor, responsible for investigating and advising on matters involving potential violations of the Foreign Corrupt Practices Act.
I spoke last Thursday with Adam S. Lee, the Special Agent in charge of the U.S. Federal Bureau of Investigation’s Richmond Division.