Compliance Communications Blog

Compliance Wave

Recent Posts

 

"Money and Gifts Affect Decisions. Really?"


9/15/14:
This may not come as a huge surprise, but it appears that recent studies confirm the connection between gifts or money from healthcare companies and decisions by healthcare providers and even regulatory decision-makers.  According to a recent study, there was a “powerful correlation” between the voting behaviors and...

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"FinCEN's Advisory Aims at Culture"


10/15/14:
The Financial Crimes Enforcement Network (FinCEN) is not amused by recent enforcement actions against financial institutions. According to a post by Michael Volkov on 
Corruption, Crime & Compliance,  FinCEN’s frustration is based on what the agency believes are the “paper compliance programs” used by many financial institutions...

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"The C&E Reporting Dilemma"


10/1/14:
In a post on his Conflict of Interest blog, Jeff Kaplan asks a basic question: to whom does the person responsible for compliance report?  The CEO?  The Board of Directors?  The General Counsel?  Fortunately, Jeff offers some useful ways of looking at the question and the possible answers.  He also provides links to two recent...

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"DOJ's Evolving Approach to Investigating Corporate Criminal Conduct"


10/1/14:
In mid-September, Principal Deputy Assistant Attorney General for the Criminal Division Marshall L. Miller spoke at the Global Investigation Review Program about DOJ’s evolving approach to investigating “… criminal conduct when it takes place at corporations and other institutions.”   Miller said, “ … in today’s Criminal Division, we are...

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"Does a Trade Sanction Settlement Trump Monday-Laundering Charges?"


10/1/14:
A new investigation into allegations of money laundering could derail a settlement with Germany’s Commerzbank to resolve US trades sanction violations.  A post by Richard L. Cassin on the FCPA Blog reviews an article in the Wall Street Journal (a link is provided but access to the WSJ requires a subscription) about...

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