Compliance

Seamus Heaney and Compliance With a Seat at the Table

Seamus Heaney and Compliance With a Seat at the Table

When assessing compliance challenges ahead of an expansion into a new market, the CCO or compliance practitioner has quite the job on his or her hands. Tom Fox offers up four basic questions to consider when walking through analysis, third-party due diligence and developing a plan to ensure ongoing compliance both with the FCPA and any in-country regulatory requirements.

Compliance Attitudes in High-Risk Markets

Compliance Attitudes in High-Risk Markets

That a certain market is high-risk is no reason not to do business there. If entering into the Russian or Chinese market, for example, can be financially advantageous, your CCO ought to be able to develop a program and budget to prevent and detect violations there. The catch is that the CCO must be involved in the discussions regarding whether...

The Hidden Nexus Between Compliance and Reputation

The Hidden Nexus Between Compliance and Reputation

The health care industry has been no stranger to the consequences - reputational and financial - of non-compliance over the past few years. The entities that have managed to maintain good standing with the OIG have also enjoyed a continued positive public reputation. Those that have been found guilty of significant infractions (GSK, Johnson & Johnson, Stryker) are paying dearly.

Consequences of a Data Breach: Lessons from Wyndham Worldwide

Consequences of a Data Breach: Lessons from Wyndham Worldwide

Between 2008 and 2010, Wyndham was subject to three data breaches, exposing more than 600,000 of its consumers and leading to millions in fraud loss. Its shareholders filed action against the Board earlier this year, alleging negligence, and a decision (dismissal) was reached in late October. Though Wyndham's leadership was not ultimately held liable in this case, there's much to...

Q&A With Roy Snell, CEO of HCCA and SCCE

Q&A With Roy Snell, CEO of HCCA and SCCE

CCI's Founder and CEO, Maurice Gilbert, recently connected with Roy Snell, CEO of he Health Care Compliance Association and the Society of Corporate Compliance and Ethics. Roy had some excellent insights to share on the state of the compliance profession, and when an expert with experience and credentials such as his weighs in, we sit up and take notice.

Does Your Compliance Policy Matter to the Antitrust Division?

Does Your Compliance Policy Matter to the Antitrust Division?

It appears the Department of Justice may be changing its tune on what makes an "effective" compliance program. Recent statements by authorities at the DOJ's Antitrust Division signal a shift in tone for the agency, toward leniency and away from a strict, hard-line approach. Read more about the apparent change here and what it could portend for your organization.

Criminal Liability of Legal Entities in Ukraine: Law in Action or Another Failed Attempt?

Criminal Liability of Legal Entities in Ukraine: Law in Action or Another Failed Attempt?

Ukraine has certainly had its share of difficulty in dealing with corruption. Among its challenges has been the apparent stunted attempt at holding legal entities criminally liable for their representatives' wrongdoing. Though legislation was put in place nearly 18 months ago establishing the criminal liability of legal entities, no enforcement in this vein has yet been handed down.

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