DOJ

shady-guy

Something is Rotten in Denmark or Is It the Banking Industry?

“Something is rotten in the state of Denmark” is one of the signature lines from Shakespeare’s play Hamlet. I thought about that when I read recent articles, “Questions Are Asked of Rot in Banking Culture” and “Lawmakers Tell Justice Dept. to Seek Swiss Banker Extraditions.”

man in suit behind bars

FCPA Year in Review 2013, Part 2

As demonstrated below, the sentences handed down in 2013 were a mixed bag, and (except for Frederic Bourke) all individuals cooperated with the government to some extent.

harriet-tubman

Harriet Tubman and Navigating to Become an Ethical Company

March 10th was the 101st anniversary of the death of Harriet Tubman. She was one of the greatest conductors on the Underground Railroad, which took slaves out of the old south and up to freedom in the north and into Canada. I read about her as a child and her story always moved me.

corporate-compliance-and-ethics-programs1-680x247

FCPA Year in Review 2013, Part 1

Foreign Corrupt Practices Act (FCPA) enforcement activity in 2013 was robust, with the DOJ and SEC bringing 31 new FCPA enforcement actions, exceeding 2012’s total of 25.

investigation protocol

What is Your Board’s Investigation Protocol?

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises. However, many Boards do not have the same rigor when it comes to an investigation, which should be conducted or led by the Board itself.

car bomb

The FCPA and Fight Against Terrorism

I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in DOJ and SEC enforcement of the Foreign Corrupt Practices Act (FCPA).

justice is blind

Three Keys to an Effective Disciplinary Program

The Justice Department and the SEC have underscored the importance of a company maintaining a clear disciplinary process so that executives, managers and employees are aware that a violation of the corporate code of conduct or the law will result in disciplinary action.