2/23/18:
Companies may know about the risks of noncompliance from their own national regulators or even transnational laws, but the consequences of noncompliance reach all the way to major global funding organizations. According to a post by Richard L. Cassin on the FCPA Blog, The World Bank has debarred three Argentina-basedconstruction companies for
2/23/18:
CMS’ Medicare Advantage (MA) represents a lucrative opportunity for many healthcare companies. It’s also a growing opportunity as Medicare beneficiaries increasingly choose it over traditional Medicare. So, when CMS estimates that it overpaid MA organizations about $1.4 billion
2/23/18: Most discussions about bribery of government officials involves the Foreign Corrupt Practices Act, but Michael Allen Braun provides a different lesson for US government contractors as he heads to jail for 18 months. The sentence was for Braun’s conspiracy to commit theft of honest services, wire fraud and bribery of a US public official – not a foreign government official. His co-conspirator,
10/6/17: An article posted by Cindy Hofmann on KPMG’s Expert Blog tackles one of the most difficult challenges facing compliance managers of global companies: third-party risk. She offers five steps to identifying and mitigating third-party risk, beginning with getting the right information about third parties. Hofmann’s suggestions include we should all remember (like, “Don’t rely exclusively on English searches” for information). The article is worth reading as a reminder for compliance professionals of what they already know but may not be top-of-mind.
10/6/17: Chief Compliance Officers have enough to occupy their time without worrying that there’s a flashing target on their backs. In an article on the Compliance & Enforcement website of New York University School of Law’s Program of Corporate Compliance and Enforcement, Patty P. Tehrani, Esq. points to a trend of increasing liability for CCOs in the financial sector. Tehrani focuses on several factors that may be contributing to the trend including regulatory expectations and enforcement actions. Fortunately, she also gleans practical lessons that may help compliance professionals remove – or at least lighten – the “targeting trend.”
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