Compliance Communications Blog

 

"SFO Director Green Talks Enforcement"


12/2/14:
For folks who missed the Pinsent Masons regulatory conference in London this fall, Richard Cassin gives an overview on his FCPA blog of David Green’s comments (the chief of the UK Serious Fraud Office). Green admitted that fraud was up – an all-too-familiar reality for compliance professionals – but so is enforcement by the UK’s Serious...

VIEW THE FULL POST


 

"One for You, One for Me"

11/15/14: Bid-rigging has become a familiar antitrust crime but the guilty plea by Aisin Seiki Co. Ltd., a Japan-based automotive parts manufacturer, resulted from its role in a conspiracy to allocate customers.  That plea agreement is costing the company $35.8 million. The scheme, according to the US DOJ, involved meetings and conversations between...

VIEW THE FULL POST


 

"How DOJ Sees Compliance Programs"


11/1/14:
In his Conflicts of Interest blog, Jeff Kaplan posted an article drawn from the keynote address given by Marshall Miller from DOJ’s Criminal Division Practicing Law Institute’s Advanced Compliance & Ethics Workshop. Kaplan quotes Miller about a high-level commitment as a principal hallmark of an effect compliance and ethics...

VIEW THE FULL POST


 

"A Primer in What Not to Do"


10/15/14:
The US Department of recently filed suit against a pharmaceutical company and its founder, owner and Chairman of the Board for violations to the Federal Food, Drug and Cosmetic Act (FD&CA) by manufacturing and distributing “adulterated and misbranded medical devices.”  By itself, DOJ’s decision isn’t groundbreaking news but...

VIEW THE FULL POST


 

"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...

VIEW THE FULL POST