Compliance Communications Blog

Compliance Wave

Recent Posts

 

DOJ Tightens Relationship with UK Agencies

1/4/16: Many aspects of regulation and enforcement are likely to change in the upcoming years, but the only place to start is where we are now and that is DOJ’s enhanced cooperation with the UK’s Serious Fraud Office (SFO) and Financial Conduct Authority (FCA). 

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New Separation Agreement Doesn't Produce Compliance

1/4/16: Two settlements with the US Securities and Exchange Commission (SEC) – one with a technology company and the other an oil and gas company – gave evidence that the federal agency has taken protection of whistleblowers seriously. 

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The Legacy of Enron

1/4/16: It’s been a long time since the Enron corruption scandal made front page news but, according to an article published in the Harvard Law School Forum on Corporate Governance and Financial Regulation, the company’s experience continues to provide lessons for compliance professionals.

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Why Compliance Officers Need to Examine Sales

12/1/16: Tom Fox’ November 27 post on the FCPA Compliance and Ethics website (“Spikes in Sales and Compliance”) drills into the case of Wells Fargo to focus on a core compliance issue:  “Every Chief Compliance Officer (CCO) and compliance practitioner understands that the sales side of a business is where the highest risk is located because that is most generally the side of the business which generates the most money and potential profit.”  Yes, but here’s the upshot.  Fox writes that looking at sales numbers is “… not something which compliance professionals will generally have access to as a part of a compliance program.

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How Does It All Go So Wrong?

12/1/16: The website JDSUPRA Business Advisor recently featured a 15-minute video of a panel discussion held at the 17th Annual Pharmaceutical and Medical Device Compliance Congress.  The panel featured compliance experts Gary Giampetruzzi and Richard Bistrong, who spoke on behavioral and third-party risk and “… how it can all go so wrong.”  Especially interesting was their discussion about red flags that should be, but often are not, recognized and addressed.  The video is both interesting and informative, even for compliance professionals outside the pharmaceutical and medical device fields.  It deserves a view.  

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