Risk and compliance self-assessments aren’t the truest indicators of actual risk exposure. So you could say there’s an inherent risk in performing a risk self-assessment. Not only is there no real science behind them, the outcome of an RCSA is entirely subject to one’s memory. A self-assessment can be a good jumping-off point, but it can’t be your sole method...
When faced with an allegation of corruption and a related investigation, your organization will be better protected by a strong compliance program – and one that requires staff to document their actions, reasoning and good faith effort to act in keeping with the law and the program. Proving corrupt intent can come down to inferences, and it’s best not to...
Olympus, the world’s largest manufacturer of optics products, has demonstrated that its culture of corruption is endemic. Having violated the FCPA, the anti-kickback statute and the False Claims Act in a bribery and kickback scandal stretching back several years, the corporation has entered into a strict corporate integrity agreement aimed at ensuring Olympus has an effective anti-corruption compliance program going...
Having violated the accounting provisions of the FCPA on several occasions, Qualcomm has been the target of an SEC investigation for some time. Last week the regulatory body concluded its enforcement action against Qualcomm, and there are some key lessons to be learned for the compliance practitioner.
To elevate “compliance” from an overused buzzword to a real value and operational commitment, leadership must empower their front-line employees to broadcast the organization’s message of ethics and compliance, and trust them to do it.
Volkswagen most certainly made a mess of things when they engineered a device to cheat emissions test, but they’ve bungled their part in the investigation as well. Thanks to the actions of some of the company’s top brass, VW has even further damage to its own reputation. The takeaway for the CCO: look at VW as a clear lesson in...
A Texas Court of Appeals has handed down a ruling in a case involving insurance coverage for the existence of and exposure to mold, and the decision does little to bring clarity to mold insurance law. Peter McGrath explores this case and others like it and what they mean for policyholders.
Real estate is one of most attractive sectors for criminals to launder dirty money due to the ease of entering and exiting the market, as well as weak regulations in the industry. This article highlights the most common schemes criminals use to launder ill-gotten money.
The annual Corruption Perceptions Index is out, and Asia-Pacific showed little improvement overall in 2015. Only a fraction of the 27 countries in the region “passed” in Transparency International’s scoring system, and while several nations did show slight increases in their scores and rankings, others took a tumble.
Global organizations have historically struggled with capturing a holistic view of their customers – one that spans international jurisdictions, lines of business, and product offerings while still allowing the corporation to maintain compliance. How does an organization standardize the definition and identification of customers when so many factors are at play?
Despite how many in front-line sales might feel, compliance and success aren’t antithetical concepts. A good compliance program is all about helping and supporting employees in the field. Doing business in compliance requires finding and bolstering the weak links, but – take it from a man who knows – considering the compliance team as partners instead of adversaries will get...
The U.S. Department of Justice's Antitrust Division gives little credit for an existing compliance program. However, a recent criminal case in Ohio establishes that the Division will credit certain compliance programs after conviction by a guilty plea or trial.
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