Archiv der Kategorie: Compliance
FCPA: Risk Assessments under the UK Bribery Act
In the February 10, 2012 edition of the Houston Business Journal, in an article entitled “In order to solve a problem, it must first be identified”, author Harvey Mackay wrote “People don’t usually buy products and services. They buy solutions … Weiterlesen
FCPA: McNulty’s Maxims, the Deepwater Horizon and FCPA Internal Controls
I often write about what I call Paul McNulty’s three maxims of a Foreign Corrupt Practices Act (FCPA) compliance program: 1) What did you do to prevent it? 2) What did you do to detect it? 3) What did you … Weiterlesen
FCPA: The Saga of MF Global – Don’t Shoot the Messenger, Fire the Chief Compliance Officer
In a post last week on his site, Corruption, Crime and Compliance, Mike Volkov named the Chief Compliance Officer (CCO) his “Person of the Year”. He did so because “There is no other position in a company which has taken … Weiterlesen
FCPA: Marc Anthony Redux-We Come Not to Praise Daimler, But to Acknowledge It
Yesterday I discussed the apparent inaction of MF Global’s Board of Directors, when the former Chief Risk Officer left the company after “repeated clashes” with company CEO Jon Corzine, over Corzine’s risk strategy. Today we take a look at a … Weiterlesen
FCPA: Boards of Directors and Compliance: Four Areas of Inquiry
In an article in the December 2011 issue of Compliance Week Magazine, entitled “Board Checklist: What Every Director Should Know”, author Jaclyn Jaeger reported on a panel discussion at the Association of Corporate Counsel’s 2011 Annual Meeting, held in October. … Weiterlesen
FCPA: [New post] From Whistleblower to RICO Claimant
The holiday season is past and many of us have returned to work. However, if you are a Chief Compliance Officer (CCO) there is a gift that you may wish to give yourself, it is “The Whistleblower’s Handbook – A … Weiterlesen
United States: EU Trade Law Compliance: Risks For US Companies Dechert
Does your company supply customers across the Atlantic? Do you procure items from a transatlantic supplier? Do you employ EU nationals? Do you have a branch, representative office or subsidiary based in the EU? More to read under […] United … Weiterlesen
Kurzübersicht über die US-Sentencing Guidelines (Compliance)
Alle Welt spricht von Compliance. Die USA (bzw. die US Sentencing Commission (USSC) haben seit 1991 spezielle Richtlinien, die die Bestrafung von Unternehmen für kriminelles Verhalten regeln. Kann im Falle eines festgestellten Verstoßes gegen Gesetze das Unternehmen die Einhaltung gewisser, … Weiterlesen
