Archiv der Kategorie: Compliance USA
SEC Sanctions Company for Whistleblower Retaliation
I drove my daughter to the airport today for her summer exchange program in Spain. On the way she asked me what I was going to blog about tomorrow and I told her whistleblowers. She was not familiar with that … Weiterlesen
The Magna Carta and Scrutiny of Your Compliance Program
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The HP FCPA Settlement
Last week the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly announced the conclusion of a Foreign Corrupt Practices Act (FCPA) enforcement action against Hewlett-Packard Company (HP). In the settlement, HP agreed to pay $108MM in fines, … Weiterlesen
Joint Venture Partners and the Company You Keep Under the FCPA
As the father of a teenage daughter I am sometimes, reluctantly, forced to admit that upon rare occasions my parents were right about a few things. One was asking for permission first rather than asking for forgiveness after the fact, … Weiterlesen
When to Bring in Investigative Counsel and Why
When should you bring in a true outsider to handle an internal investigation? What about specialized investigative counsel? Jim McGrath, who often writes about the need for specialized investigative counsel, has also pointed out on several occasions that having an … Weiterlesen
Getting Your Company Ready for M&A Compliance Due Diligence
Who was the absolute worst general during the Civil War? While there are many worthy candidates for this dubious honor, on the Southern side my vote goes to General John Bell Hood. One of the prime proponents of the Southern … Weiterlesen
Five Golden Rules of What Works – The Internal Marketing of Compliance
I am attending the ACI Foreign Corrupt Practices Act (FCPA) Boot Camp in Houston. It is one of the best FCPA events held in Houston annually. It brings together some of the top local compliance talent, together with top national … Weiterlesen
How Straight From The Lion’s Mouth Informs Your Hotline
The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens … Weiterlesen
Froome Wins the Tour and a Victory for Law Firms on Their Privilege
Yesterday Chris Froome won the 100th incarnation of the Tour de France. He held the leader’s position, as signified by wearing the Yellow Jersey, since Day 8 of the Tour. Froome is the second Englishman to win the race in … Weiterlesen
Don’t Claim it is Legal to Bribe Another Government’s Representatives – Especially in China
Last week a guest blog post in the FCPA Blog by Ernesto Sanchez, entitled “What’s good for reciprocity may be bad for FCPA prosecutions”, implied that the US District Court’s ruling when it “vacated an SEC Dodd-Frank rule mandating that … Weiterlesen
