We should all anticipate — with optimism but also serious preparation — a post-quarantine return to business, and appreciate that a return to “normal” business will actually mean in practice a period of frenetic efforts to make up for lost time and lost revenue, with accordingly severe demands on compliance professionals.… Continue Reading
The Joker has been adopted as a symbol of rebellion against perceived corrupt power structures worldwide. If one makes the leap to understanding global protest movements as a systemic response to perceived institutional corruption, then it is not so far to see the connection.… Continue Reading
As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws. However, if the DOJ or state regulators discover that a license was acquired through corrupt means, the license will not provide any protection.… Continue Reading
Preet Bharara gave the morning keynote at the second day of Compliance Week 2019. It was interesting because rather than a speech he did so with a one-hour Q&A format with Allen & Overy partner Gene Ingoglia facilitating the session through the role of the questioner.… Continue Reading
Today I write from Berlin, staying in what was old East Berlin. Last week I spoke at an event in Malaysia. Both societies that have experienced and are experiencing (respectively) political, social and economic change that was once unimaginable.… Continue Reading
For companies that are serious about being proactive and that see compliance as a competitive advantage rather than a box-ticking exercise, we believe several lessons can be drawn from our background in helping organizations see around unexpected corners — whether those be geopolitical in nature, compliance related or high-stakes security and risk.… Continue Reading
In a January article in the French financial newspaper Les Echos, entitled “Salaries: compliance can pay big,” journalist Delphine Iweins reported that according to a 2019 compliance compensation study by the French firm Atorus Executive, 35 percent of the responding enterprises are now confident in legal compliance officer and compliance manager positions.… Continue Reading
These days, I sometimes begin my classes on corruption with an unusual admission. I announce to my students — who may be judges, police officers, military investigators, bureaucrats or any other variety of public official — that corruption is not a problem removed from me.… Continue Reading
Nearly every corporate anti-bribery violation reveals problems with internal controls.
Again and again SEC enforcement actions describe devious employees who were able to subvert the controls and thereby create slush funds and pay bribes, or controls that were weak to begin with and incapable of detecting or stopping the corrupt actors.… Continue Reading
Denise Lee Yohn is a go-to expert on brand-building for national media outlets. She’s also a popular speaker and consultant, and an influential writer.
As the United Nations Global Compact discusses in their business anti-corruption guide, centralized and decentralized models have their own strengths and weaknesses with regard to control, consistency and understanding of local nuance.… Continue Reading