Jeffrey M. Kaplan is a partner in the Princeton, New Jersey office of Kaplan & Walker LLP. He has specialized since the early 1990s in the practice of compliance- and ethics-related law, including assisting numerous companies in developing, implementing and reviewing C&E programs and conducting C&E risk assessments. He has also reviewed programs for many official bodies in connection with settlements of enforcement actions. He is the co-author of a C&E legal treatise, author of several e-books — including “Compliance & Ethics Risk Assessment” — and book chapters and many articles on C&E, a frequent speaker at C&E conferences, editor of the Conflict of Interest Blog and formerly an Adjunct Professor of Business Ethics at NYU’s Stern School of Business.
Rebecca Walker is a partner in the law firm of Kaplan & Walker LLP, a firm that specializes in corporate compliance and governance located in Santa Monica, California, and Princeton, New Jersey. For over 20 years, Rebecca has specialized in advising clients on the development and implementation of compliance programs. She has also served as a monitor for the Department of the Air Force and as an independent consultant, reviewing programs for the U.S. Securities and Exchange Commission.
Rebecca is the author of “Conflicts of Interest in Business and the Professions: Law and Compliance,” published by Thomson West, as well as numerous articles and studies. She chairs the Practising Law Institute’s Compliance and Ethics Essentials Institute in New York and the Advanced Compliance and Ethics Workshop in San Francisco and serves on the Advisory Board of “Compliance and Ethics Professional” magazine. Rebecca received her B.A. from Georgetown University and her J.D. from Harvard Law School.
The DOJ doesn’t take kindly to recidivism. Jeff Kaplan and Rebecca Walker discuss the importance of a “lessons learned” approach to your organization’s compliance and ethics program. “Those who do not remember the past are condemned to repeat it,” famously wrote philosopher George Santayana. But what exactly – of the past – should be recalled? The need to explore violations of law...
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How recently has your organization evaluated its guardrails to protect against conflicts of interest? Most companies need work in this area. Jeff Kaplan and Rebecca Walker cover how to conduct a conflict of interest assessment. Many compliance and ethics (C&E) program assessments are of what might be considered a general scope – meaning they are not focused on a particular area of...
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Whatever “flavor” of compliance incentives you offer, they need to be reassessed regularly. Jeff Kaplan and Rebecca Walker discuss what to take into account. The Sentencing Guidelines provide, in relevant part: “the organization’s compliance and ethics program shall be promoted and enforced consistently throughout the organization through … appropriate incentives to perform in accordance with the compliance and ethics program….” Providing discipline...
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Jeff Kaplan and Rebecca Walker inaugurate what will be a regular column on compliance & ethics program assessments. Most of our posts will be focused on the “how” of assessing C&E programs, but here, we begin by exploring the “why.” Legal Mandates and Guidance Some of the most powerful drivers for assessments are legal. The first and most influential of these is...
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