Compliance Communications Blog

 

"Best Practices Compliance Programs for 2016"


11/3/2015: Tom Fox’s recent post on his FCPA Compliance and Ethics blog focused on the issue of “… training and testing the effectiveness of a best practices FCPA compliance program.”  Employee training has always been an integral component of an effective compliance...

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"Beyond Fines: Responding to Corporate Misconduct"


11/3/2015: If the threat of multi-million dollar fines isn’t enough to discourage corporate wrongdoing, what is? The question has swirled around since the DOJ ramped up its anti-corruption enforcement efforts. Billions of dollars have been returned to the federal purse but very few...

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"Subject: Individual Accountability for Corporate Wrongdoing"

 

9/15/15: That’s the subject line in a recent memo from DOJ to federal prosecutors.  The memo spells out a new policy for aggressively investigating and prosecuting individuals involved in corporate crimes. In a notable shift from DOJ’s traditional focus on prosecuting corporations, the memo sets...

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"Declination May Not Be the End"

 

6/16/15: Declinations are usually perceived as the end of an enforcement action but recent actions by US enforcement agencies show otherwise. According to a post by Richard Cassin on the FCPA Blog, the US Securities and Exchange Commission recently notified NET1 UEPS Technologies that it declined to recommend...

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"A Dirty, Beautiful Mind"

 

6/5/15: Even if the FIFA World Cup doesn’t give you an adrenal boost (only two more years until the 2018 games, after all), the corruption scandal hitting world soccer’s governing body has rattled the cages of national governments and private companies alike. The indictments are likely to grow as...

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