Menu10/1/14: 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...
Compliance Communications Blog
Oct 01, 2014 •
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...
Oct 01, 2014 •
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...
Oct 01, 2014 •
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...
Sep 30, 2014 •
Reflect, for one moment, on just how much you know about McDonald’s. (It doesn’t matter whether you love McDonald’s or would never be caught dead in one; this works either way.) You know the names of many of their foods. You know that an Egg McMuffin is eggs on an English muffin with cheese and Canadian bacon, and if you made a sandwich at home that looked like that you might have to resist the urge to call it an Egg McMuffin. You probably even know that the Shamrock Shake only comes around at certain times of the year, and you will remember the Hamburglar and Ronald McDonald for the rest of your life.
AND YET: You have never read a single policy related to Big Macs. You have never received annual training on eating Chicken McNuggets. You have never signed a Certification that says that you know who Grimace is and that you agree that he is a big, affable purple guy.
Sep 15, 2014 •
9/15/14: Most global companies grew up under the shadow of anti-corruption laws that criminalized the “giving side” of bribery. Bribes by employees or third parties to foreign government officials have been the focus of investigations, prosecutions and settlements in the millions or even billions of dollars. But, for every individual paying a bribe, there is...
