History might be told a bit differently if risk conduct analyses were common practice. These days, there's as much need as ever to address conduct risk, setting policies, incentive structures and enforcement practices in our organizations that reward good conduct and penalize acting contrary to the companies' values and regulatory standards.
The GSK China scandal came to light through a sex tape, and the anonymous whistleblower who leaked the tape also presented allegations of bribery. GSK's own investigation into the matter has failed to net anything of substance, but the Chinese government has turned up a great deal of evidence pointing to massive systemic bribery.
In the past month, we've heard plenty of allegations of corruption associated with the Brazil World Cup, but there's as much or more controversy surrounding the forthcoming events in Qatar. Tom Fox suggests that when there's a question of corruption, just follow the money. And in this case, it's flying in all sorts of questionable directions.
GlaxoSmithKline has gotten plenty of negative attention lately for allegations of widespread corruption in its China operations, accusations that may cause irreparable harm to the pharma giant. Regulatory bodies far and wide are jockeying for position to charge GSK, sending the message that corruption will not be tolerated. Compliance practitioners, take note!
When assessing how effective your compliance program is, step into the regulators’ shoes. What are they looking for? Current and former high-level staff at the DOJ and SEC have keen insight into the issue. Does spending line up with compliance priorities? What do the roles of your legal and compliance departments say about your commitment ...
An in-depth analysis of the recent decision by the 11th Circuit Court of Appeals, with a handy guide to determine what constitutes an instrumentality. There are plenty of factors at play in making these determinations, but – lucky you! – we have an expert on hand to illuminate the matter. Tom Fox deep dives into the Esquenazi ...
An opinion released Friday by the Court of Appeals offers some much needed clarity on just what organizations are considered “instrumentalities” under the Foreign Corrupt Practices Act. Here, Tom Fox explores this decision, as well as early amendments to the FCPA supporting the Court’s findings and methods for establishing instrumentaility. The findings seem to be based entirely ...
The changes Presidents bring to pass in their first 100 days in office have long been the measure of their success early on. Like our commanders in chief, our CCOs should aim to hit the ground running, quickly establishing themselves as champions of ethics and compliance. The first orders of business for new CCOs: use all resources ...
I thought about Willie Nelson when I came across a recent release by the UK company Arachnys Information Services Ltd (Arachnys), entitled Open Data Compass, about their tool designed to help businesses identify "information blind spots and evaluate online access to corporate, litigation and news records from emerging markets."
While your compliance focus group may not be quite the game changer that the Louisiana purchase was for the U.S., it will certainly provide you solid information on your compliance program that you can use to move it forward.
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