News and commentary about white-collar crime, enforcement, and compliance
Harry Cassin
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As the leader of a private company, WeWork’s former CEO Adam Neumann clearly wasn’t subject to strong expense reporting requirements or conflicts of interest processes — he threw extravagant parties, routinely hired his family members and close friends, and engaged in numerous related-party transactions.… Continue Reading
Last week the transcript from Tim Leissner’s August 28 plea hearing was unsealed and posted online, courtesy of the Financial Times.
Mr. Leissner was a managing director of Goldman Sachs and chairman of its Southeast Asia operations.… Continue Reading
The best primary source material for creating and maintaining an anti-corruption compliance program is still Chapter 8 of the U.S. Federal Sentencing Guidelines.
It describes the elements of an “effective compliance program” — a legal term of art with the specific meaning assigned to it by the Sentencing Guidelines.… Continue Reading
Former Louis Berger executive James McClung was sentenced this month to a year and a day in jail for violating the FCPA. If “a year and a day” sounds familiar, it should.… Continue Reading
Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.… Continue Reading
I’ve been attending the HCCA’s 19th Annual Compliance Institute this week in Lake Buena Vista, Florida.
The Health Care Compliance Association is a non-profit membership group for compliance professionals in the healthcare-provider field.… Continue Reading
Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991.… Continue Reading
The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda:
10.… Continue Reading
We provided a number of examples in the prior post when the DOJ funded community service projects with settlement money while fully complying with the MRA. Indeed, these projects have become more common, not less, in recent years.… Continue Reading
Author Scott KillingsworthAchieving consistent legal compliance in today’s regulatory environment is a challenge severe enough to keep compliance officers awake at night and one at which even well-managed companies regularly fail.
A truly “egg-gregious” case settled last week with guilty pleas by the company and two top officers.
According to the DOJ’s press release, Quality Egg LLC bribed health inspectors and marketed misbranded, falsely labeled eggs, adulterated with salmonella bacteria.… Continue Reading
The FCPA Blog wanted to explore the idea of the dual-hatted compliance officer — the one who occupies both the general counsel and chief compliance officer roles in a company. We talked with the former SEC Chairman and now Kalorama Partners CEO, Harvey Pitt.… Continue Reading