Blog Posts Tagged with "FCPA"
December 05, 2012 Added by:Thomas Fox
The five essential features are based on the Department of Justice’s thinking on the issue in the form of the US Sentencing Guidelines, FCPA enforcement actions and evolving best practices. If your company is not following these it may well not be deemed to have a commitment to compliance...
November 04, 2012 Added by:Mary Shaddock Jones
In my experience, companies need to be closely reviewing what little case law or factual allegations exist with regard to the FCPA so that they too know where to find any potential problems that may exist within their own company. There are only so many ways to hide the dollar...
October 29, 2012 Added by:Thomas Fox
I recently saw a White Paper released through Compliance Week, where an un-named author posited that there are seven essential features to create an effective hotline. I found this article to be useful for a compliance practitioner to quickly review how his or her company might set up a hotline...
July 25, 2012 Added by:Thomas Fox
As the compliance field evolves, the need for experienced professionals continues to grow, there is the need to hire top notch compliance talent to do the day-to-day work of implementing, enhancing or running a compliance program. Where can you go if you want to hire some experienced compliance professionals?
July 09, 2012 Added by:Thomas Fox
The DOJ recently announced the resolution of a compliance matter involving violations by Data Systems & Solutions LLC. In reading the Criminal Information, this was no one-off or rogue employee situation, this was a clear, sustained and well known scheme that went on within the company...
June 25, 2012 Added by:Thomas Fox
New York Times reporter Adam Bryant recently profiled Angie Hicks, one of the co-founders of Angie’s List, who has some interesting observations on leadership that I found applicable to creating a functional compliance effort within an organization, from compliance professionals to ethical leadership...
June 25, 2012 Added by:Headlines
Data Systems & Solutions LLC, a company based in Reston, Virginia, that provides design, installation, maintenance, and other services at nuclear and fossil fuel power plants, has agreed to pay an $8.82 million criminal penalty to resolve FCPA compliance violations...
May 31, 2012 Added by:Thomas Fox
The ABA Primer notes that an effective compliance program consists of documentation that an organization “exercise[s] due diligence to prevent and detect criminal conduct; and otherwise promote[s] an organizational culture that encourages ethical conduct and a commitment to compliance with the law”...
April 29, 2012 Added by:Thomas Fox
I was thinking about Captain Kirk and his leadership of the Enterprise in the context of issues relating the Board of Directors responsibility in a company’s compliance program. Kirk did not have to deal with a BOD, but he did lead from the front, and that is what a CCO must do...
April 17, 2012 Added by:Thomas Fox
Management must “walk the talk” through both discipline and a system of rewards. The discipline must be clear and delivered decisively. The rewards must be not only direct financial remuneration but also the internal promotion of persons who do business in an ethical manner...
April 11, 2012 Added by:Thomas Fox
There is an ongoing debate in the compliance world about whether a company can or should combine or separate the role of the CCO from that of the General Counsel. Before a company can answer this question, it must meet No. 6 of the DOJ's minimum best practices requirement...
March 26, 2012 Added by:Thomas Fox
Can compliance be innovative? Or can innovation inform your compliance program? Innovation in the compliance arena is key. As compliance programs mature and as companies mature in their approach to compliance, innovation will continue to lead best practices...
March 21, 2012 Added by:Thomas Fox
A mature compliance program can be a great benefit for a company, not only in evaluating risk from the compliance perspective but also preparing the necessary steps so that if a contact is awarded, it can be executed in an efficient manner. But it must have a seat at the table...
March 19, 2012 Added by:Mary Shaddock Jones
The cost of implementing a compliance program will vary, however, it isn’t expensive enough to find yourself in front of the DOJ explaining why you spend money on air travel or paper clips than you do on a compliance program. Trust me, you don’t want to be in that position...
March 05, 2012 Added by:Thomas Fox
One of the areas moving towards being incorporated into compliance programs is the supply chain. While many companies have focused significant compliance efforts towards the sales chain, the supply chain is now viewed as an area which requires compliance scrutiny...
December 09, 2011 Added by:Thomas Fox
A company should look for small ways to expand employee autonomy in the compliance area. This does not mean a complete abdication of the role of the Compliance Department, but it does mean a notch-by-notch transfer of authority to persons in the field...
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