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
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
Assistant 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 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
Achieving 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.
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