Risk assessment and program assessment are, of course, two different animals. But inside most every risk assessment there is a program assessment struggling to be heard, and the converse is true of every program assessment. Making the most of these connections can be essential to optimizing both functions. There are several ways to do this, and Jeff Kaplan focuses ...
We do not know for sure why Tyco received only a non-prosecution agreement instead of a deferred prosecution agreement, or how it avoided a monitor. But the treatment is notable. Matteson Ellis explores reasons why Tyco didn't get a harsher punishment.
Tyco agreed to a robust corporate compliance program that either currently exists or will be implemented in the future. This corporate compliance program is somewhat different than most of the 13 minimum best practices compliance regimes reported in DPAs and NPAs since the Panalpina DPA of November 2010. Thomas Fox reviews what it consists of.
FCPA professor Mike Koehler provides us with a round up of all things FCPA. There's talk of Wal-Mart, recent survey results, quotes from former DOJ employees, and more.
How good is your antitrust compliance program – would it be considered effective in addressing criminal antitrust risk, or what is also referred to as cartel conduct? Perhaps you have an antitrust manual and a lawyer who gives presentations about the law. Maybe this is also covered in your code of conduct. But does this meet the most widely ...
John “The Fraud Guy” Hanson answers three reader-submitted questions, providing his perspective as an independent corporate monitor.
Steve Priest reviews the lessons from the NFL referee fiasco and how it relates to the tragic flaw underlying most of our corporations, the relentless drive to improve profitability. This can be good, but sometimes, usually when arrogance overcomes prudence, people and companies do stupid things in the name of profitability.
Germany developed its first attestation standard for compliance programs, which on one hand gives guidance for a general accepted compliance program framework and on the other hand gives assurance on the program itself. Ernst & Young's Andreas Pyrcek reviews it.
The authenticity of your company’s compliance regime is driven by how well your employees buy in to the concept of doing business in a compliant manner.
Baker Donelson's Doreen Edelman explains what the Office of Foreign Assets Control is, which businesses need to be concerned about its sanctions, how to comply, and what the penalties are.