Risks change over time. Companies developing C&E plans for 2013 may wish to conduct a refresher risk assessment if they have not done so recently…
Many of Marshall’s qualities transcend the military and are useful when evaluating employees to become compliance practitioners or Chief Compliance Officers.
Egil “Bud” Krogh, Jr. Mr. Krogh was the Deputy Assistant to President Richard Nixon who also headed Nixon’s Plumbers. The Plumbers was the group initially set up to “plug” the Nixon Administration’s news leaks. As history tells us, its purpose morphed into illegal activities, like the Watergate break-in. Mr. Krogh is a particularly relevant person to comment on the challenges of the FCPA compliance officer.
It remains a challenge for corporations to balance the ethical demands of regulators with the pursuit of profit. Sustainable growth can be achieved but it requires determination over several years rather than focusing simply on short-term profits and personal remuneration.
Companies respond differently to compliance challenges, particularly in the way in which they encourage and embrace whistle-blowers.
Every company knows that its internal auditing function is the lifeblood of its compliance program. Some companies carry that to an extreme by placing the overall compliance function in the auditing department. As we all know, that is a mistake.
October 16 is the anniversary of John Brown’s Raid on Harper’s Ferry. For those of you not familiar with this episode of American history, abolitionist John Brown led a raid on the US Arsenal at Harper’s Ferry, Virginia, the raid was intended to foment an armed slave revolt in 1859. Brown’s raid was defeated by a [...]
Robust FCPA enforcement over the last several years has had some obvious effects. But less obvious, and perhaps more surprising, has been the effect of FCPA enforcement on foreign state-owned enterprises (SOEs), the entities that are often the recipients of the bribes themselves. And this might matter to FCPA compliance. Matteson Ellis reviews three recent developments that have resulted from FCPA enforcement.
In December 2011, the DOJ and SEC brought related FCPA enforcement actions against Magyar Telekom and Deutsche Telekom alleging various bribery schemes in Macedonia and Montenegro. As reported last week, lawyers for the defendants argued last week at an initial appearance in the U.S. District Court (S.D. of New York) that the court lacks jurisdiction over the defendants.