Why an alert about doing business during an investigation?… Continue Reading
“Over the last decade, since the passage of the Sarbanes-Oxley Act in 2002, publicly traded corporations have poured significant resources into their compliance programs to prevent wrongdoing, or to at least be an early warning system for what might become a problem.… Continue Reading
I’ve argued in this series that freedom from bribery is a human right, and that FCPA enforcement should do more to protect those rights.
Only five years ago, no one talked about self disclosing potential FCPA violations.
Today, a mere blink of an eye later, self disclosure is the norm.
In our era of hyper-enforcement and Sarbanes-Oxley driven field certifications, the new pattern is set:
Hear from a whistleblower about sensitive payments somewhere, take a quick look for credible evidence, inform the board, launch an internal investigation, disclose it to the DOJ, and write it up in the next quarterly SEC filing.… Continue Reading