Compliance Officer

By JD Supra Business Advisor | JD Supra's magazine on corporate compliance matters: FCPA, bribery, SEC enforcements, and more. Updated daily.

I Was An Irrational Compliance Calculator

In what might be described as a “companion guide” to my <i>Ethikos</i> article <i>Does Compliance Need More “Darkside,”</i> I had a chance to read Scott …

The Best Compliance Reads Are Not About Compliance

Lately, during a number of webinars and speaking engagements where I frequently cite the work of what I consider to be thought leaders in …

Pow! Whack! Slam! Bam! – DOJ Finishes the FCPA Year with a Bang

Follow-On Individual Prosecutions: The Avon investigation is still continuing as to criminal prosecution of several former senior executives who were …

Success Without Corruption in Africa

In a Bryan Cave blog piece (link here) “Corruption costs: why your business needs an anti-corruption strategy if you are investing or operating in …

Africa

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"My best business intelligence, in one easy email…"<p>Your first step to building a free, personalized, morning email brief covering pertinent authors …

LinkedIn

Revealing Whistleblower’s Identity is Retaliation

The United States Court of Appeals for the Fifth Circuit held that revealing a whistleblower’s identity is prohibited retaliation under the …

Halliburton

Former SEC Chairman Roderick Hills And The FCPA

Roderick Hills, who passed away at the end of last month, served as Chairman of the SEC through one if its most turbulent periods – the birth of the …

21st Century

What happens when business strategy becomes a red-flag for bribery?

<b>The following is a Q and A with Richard Bistrong and Ethic Intelligence, which was published in</b> <b>Ethic Intelligence, Expert Corner, in May 2014. It</b> …

Rationalizing Risk: Compliance as "Bonus Prevention"

As part of my series on “Rationalizing Bribery,” I now turn to the issue of personal incentive compensation. <b>As tweeted by Ben DiPietro,</b> …

Wall Street

“Our Website Is Down” Does Not Suspend Compliance

The economy being what it is, a young relative of mine was thrilled to get a job in the coffee bar of a local bookstore. What’s more, they were …

Employment

Esquenazi Appeal Confirms the Broad Reach of the Foreign Corrupt Practices Act (FCPA)

In last month’s closely watched <i>Esquenazi</i> decision, a U.S. court of appeal weighed in on the definition of “instrumentality” under the Foreign Corrupt …

Government

Does Data Discriminate? Perspectives for Employers on the White House's Recent "Big Data" Report

Last month, the White House released a comprehensive report on the use of “big data” in the public and private sectors. Employers should pay …

Data Management

Essential Requirements For An “Effective” Ethics and Compliance Program

A client recently reminded me – “Mike, it is not just an ethics and compliance program, it is an “effective ethics and compliance program.” I always …

Governance

Prison Sentence in Air India Bribery Scheme Sends Deterrent Message to Canadian Executives

On May 23, Nazir Karigar, an agent of Cryptometrics Canada Inc. (Cryptometrics), was sentenced to three years in federal prison under Canada’s …

Corruption

U.S. Labor Law and Child Labor in Corporate Supply Chains

Human Rights Watch‘s recent report, <i>Tobacco’s Hidden Children – Hazardous Child Labor in United States Tobacco Farming</i>, seeks to draw attention to the …

Human Rights

SEC Settles Financial Fraud Charges With Issuer, CFO

The Commission filed settled financial fraud charges against an issuer which discovered and remediated a series of accounting issues and the CFO who …

Fraud

Conflict Minerals Rule Update: NAM Files Emergency Motion for Stay with D.C. Circuit Court of Appeals

Following through on its April 30 statement, the National Association of Manufacturers, joined by the U.S. Chamber of Commerce and the Business …

Judiciary

Deferred Prosecution Agreements in the UK: The New Frontier for Employers

Deferred prosecution agreements (DPAs) are a relatively new law-enforcement tool in the UK, only becoming effective this past February under the …

Conflict Minerals — SEC Says File The Reports — But Don’t Confess Blood On Your Hands

At the core, the court’s first amendment objection to the conflict minerals rules was that by requiring issuers to state its products have not been …

Ignore The First Conflict Minerals Filing

Securities lawyers eagerly await the first (or the first few) new filings required by law to learn (and of course copy) from them. So the first …

Get Your Tutsi Fruitsi: Calculating FCPA Fines Under The Sentencing Guidelines

The Marx Brothers’ movies will live in infamy – they were hilarious, creative, and always relevant.<p>One of my favorites was <i>A Day at The Races</i>, and the …

Trendy “Cybersecurity” Versus Traditional “Information Security” Two Sides of the Same Security Coin

Cybersecurity has become a dominant topic of the day. The Snowden revelations, the mega-data breaches of 2013, the pervasiveness of invisible online …

Cybersecurity

Expansion of Antitrust Enforcement Continues with Extradition

On April 4, 2014, the Department of Justice’s Antitrust Division announced its first successful extradition of a foreign national to the United …

SEC Files Another Settled Insider Trading Case

Insider trading continues to be a key priority in the new get tough enforcement era. Last week closed with the filing of an insider trading action …

Common Mistakes, Problems And Concerns Companies Face During Implementation And Maintenance Of Corporate Compliance Programs

An effective corporate compliance program is an essential component of internal controls for uncovering and preventing ethical lapses and criminal …

Governance

Supreme Court Expands Whistleblower Protection

The U.S. Supreme Court recently held that Sarbanes–Oxley extends whistleblower protection, not just to employees of public companies, but to …

Fraud

SEC Scrutinizing Contractual Impediments to Whistleblower Complaints

Sean McKessy (“McKessy”), the Securities and Exchange Commission’s (“SEC”) whistleblower chief, cautioned in-house attorneys who draft contracts …

Getting the Deal Through – Anti-Corruption Regulation 2014: Bermuda

1. International anti-corruption conventions:<p>To which international anti-corruption conventions is your country a signatory? -<p>Bermuda is a …

SEC Names Company, Eight Directors and Officers In Financial Fraud Actions

Since the market crisis enforcement officials have heard repeated calls to prosecute not just companies but high ranking corporate officials. While …

21st Century