Archiv der Kategorie: Compliance
The FCPA Enforcement Process: Negotiating the Penalty
I recently explored the issue of ‘extraordinary cooperation’ in the context of a Foreign Corrupt Practices Act (FCPA) enforcement proceeding and some of the concrete steps that a company could take to reduce its overall penalty assessed by the Department … Weiterlesen
Three Keys to the Role of a Chief Compliance Officer
There is an ongoing debate in the compliance world about whether a company can or should combine or separate the role of the Chief Compliance Officer (CCO) from that of the General Counsel (GC). However, before a company can answer … Weiterlesen
Compliance Self-Assessment
Die Empfehlungen des US-Justizministeriums zu Best Practices im Bereich des Foreign Corrupt Practices Act (FCPA) enthalten unter Punkt 13 die Notwendigkeit (und damit lesenswert!) der ständigen Überprüfung des eigenen Compliance Programms: „13. Ongoing Assessment. A Company should conduct periodic review … Weiterlesen
FCPA: OCEG Illustrated Series: Managing Corruption Risks
How do you move off dead center? That was a question posed by my colleague Mary Jones in a recent guest blog post. She gave several concrete steps in answer to her own question. This question was further explored in … Weiterlesen
FCPA: The BizJet DPA: Cooperation is the Key
Last week, the Department of Justice (DOJ) announced the resolution of an enforcement action under the Foreign Corrupt Practices Act (FCPA) involving the Tulsa based company, BizJet. The company is in the business of providing aircraft maintenance, repair and overhaul … Weiterlesen
FCPA: Creating Sustainable (Compliance) Performance
Compliance practitioners are continually tasked with moving a company’s culture of compliance forward. However, the day-to-day work is sometimes too granular to see results. In an article in the January-February issue of the Harvard Business Review, entitled “Creating Sustainable Performance”, … Weiterlesen
FCPA: The CCO and Crisis Management
“What, Me Worry?” is one of my favorite all-time slogans. Anyone who grew up on the 60s or 70s recognizes this comes from Alfred E. Neuman, the enigmatic face of Mad Magazine. While this phrase certainly had its uses for … Weiterlesen
FCPA: IP Rights under the FCPA
For many US companies conducting business internationally, Intellectual Property (IP) is a key business component. Not only is the development of new IP critical to many businesses, for continued growth strategies, but IP protection is now a central business interest. … Weiterlesen
The Compliance Integration Risk Assessment
For the want of a nail, the horse was lost. For the want of a horse, the message was lost. For the want of a message, a battle was lost. For the want of a battle, a kingdom was lost. … Weiterlesen
FCPA: Haas School Training for Compliance and Ethics Leadership
There are a myriad of compliance and ethics conferences across the country each year. I regularly attend and speak at some of these. There are also more regular webinar and local events which may focus on specific topics or themes. … Weiterlesen
