This post provides a roundup of commentary (law firm, individuals, and civil society organizations) relating to this week’s FCPA guidance issued by the DOJ and SEC.
Why Can’t a Company Go to Trial?
The underpinning of the Justice Department’s criminal prosecutions program against companies is based on a simple premise – a company has to negotiate a pre-indictment settlement to avoid the catastrophe which occurred to Arthur Andersen in 2002….
4 Themes for Implementing ERM
When discussing ERM and how to improve the value it adds to the enterprise, executive management and directors often ask, “Where do we start?” At the heart of this question is the desire for a simple and pragmatic point of view that makes sense in practice. For many companies, risk management has focused on protecting [...]












