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.
I’ve been looking at the role women now play in compliance in the United States and overseas. The good news is that more women have come into the ranks in top level compliance positions. But not all women have found success in those roles.
In the prior post, I looked at the presence of women in compliance roles in the United States and abroad. In this post, I’m looking at how women in compliance can be a catalyst for more diversity in organizations.
Women may or may not be better-suited to risk management roles as compared to men as being fully equipped for the role might have more to do with skills sets, ethical judgment and plain-vanilla experience than with anything related to gender.
Just as the 2016 FCPA enforcement year left us plenty of topics to discuss, the new year brings many uncertainties, and the direction of the law’s enforcement is a matter of some debate.