After more than two decades of forensics practice, I know that during any anti-corruption compliance assessment, I’ll want to spend time not only with personnel from the accounting and compliance groups, but also with human resources.… Continue Reading
Culture is often thought of as a soft issue because companies struggle to measure its effectiveness. But culture and compliance are linked.
In an FCPA context, for example, compliance failures frequently flow from the erosion of ethical behavior and robust corporate governance. … Continue Reading
In the frenzy of upsizing, downsizing and rightsizing compliance programs after downturns in the market or in the midst or aftermath of a major investigation, it’s important to keep in mind that experienced lawyers and compliance professionals bring significant value to a company.… Continue Reading
With every enforcement action comes lessons and warning tales for other companies and compliance officers. Last week Qualcomm paid $7.5 million to settle SEC charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese officials responsible for deciding whether to select the company’s mobile technology products. … Continue Reading
I’m often asked for my thoughts about the future of compliance. What people really want to know is, what’s the next level of compliance? How do we improve? For me, the answer is corporate consciousness.… Continue Reading
Corporate compliance programs are no longer classified as “nice to have,” nor are they mere responses to allegations of wrongdoing. Some companies are going beyond mentioning how they have cleared their names with regulators after an investigation; they’re actively promoting the components of an effective strategy.… Continue Reading