‘Enforcement 40’ for 2020
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Join the Securities Litigation and Enforcement Group on LinkedInAt Large: The cobra effect is an enemy of compliance | The FCPA Blog
Getting what you pay for but not what you hope for is also known as the cobra effect. During colonial rule in India, British officials came up with a plan to reduce the number of dangerous cobras in Delhi. They offered a bounty for every dead snake. Over time, more and more dead cobras were […]
June 25 Webcast: COVID-19 Pandemic-Related Compliance, Financial Reporting & SEC Enforcement Considerations
Please join Marion Duffy, Keith Halverstam, Alok Khare, Ryan Maierson, Rob Malionek, and Todd Rahn for this free webcast.
At Large: Is this the most important change in the DOJ’s new guidance? | The FCPA Blog
The DOJ’s new guidance for evaluating corporate compliance programs put the spotlight on organizational justice, or what we might simply call fairness. This question was added to Monday’s version of the guidance: “Does the compliance function monitor its investigations and resulting discipline to ensure consistency?” That new question appears under the heading “Consistent Application.” That […]
What Hath Covid-19 Wrought? A New Skill Set Required for Compliance: Part 1 – Compliance ReportCompliance Report
The Coronavirus health crisis has wrought many changes in the business world and corporate compliance. Over the next few blog posts, I want to explore in some depth what I see are the key changes for the Chief Compliance Officer (CCO), compliance professional and compliance programs as we move to reopening the country and world […]
$475M Lawsuit Alleges Danske Bank’s Inaction Created ‘Enormous Scandal’ | Corporate Counsel
At the heart of a $475 million lawsuit that investors in 19 countries have brought against Denmark’s largest bank is a lesson for legal departments regarding the importance of compliance and disclosure. “You need to take regulatory compliance very seriously and when you do have problems don’t cover it up. That will only turn it into […]
Speech: ‘Costumes, Candy, and Compliance: Remarks at the National Membership Conference of the National Society of Compliance Professionals
Some people believe that a formal enforcement action is the obvious response to every compliance infraction. In my view, a better approach is to build certain norms into the industry that foster compliance. Hitting someone over the head with a criminal conviction is a sure way to scare all trick-or-treaters, even those not breaking the […]
Compliance Thought Leaders You Should Be Following | GAN Integrity
Compiling a list of thought leaders in ethics and compliance is fun, but so challenging. There are simply too many thoughtful people in this field — which is itself enormous and wide-ranging — to call out everyone worth following. So below is a small slice of the thinkers in corporate ethics and compliance that I […]
$7 Billion Hasn’t Moved The Needle on Financial Crime: Gadfly – The Washington Post
The bigger picture is less encouraging. Despite a cascade of rules, regulations and record-breaking fines, that spending — an additional 5 billion pounds ($7 billion) a year in the U.K. alone — has barely moved the needle. Gauging success in this area may not be an exact science, but if catching dirty money is a […]
The Compliance Podcast Network – Compliance Report
Back in 2011, over a with dinner Howard Sklar, we talked about commentary on the FCPA and in the greater compliance community. That conversation led us to begin the original This Week in FCPA podcast. Howard later went off to the corporate world but I continued our podcasting tradition founding the FCPA Compliance Report in […]
The Watchdogs Keeping Wall Street in Check – The New Yorker
Despite compliance’s reputation as a buzzkill profession, its status rose during the Obama Administration. Regulations implemented after the financial crisis created a need for internal watchdogs, as did the concern raised by prosecutions of banks and hedge funds for mortgage fraud, currency-market rigging, and insider trading. In 2014, the Wall Street Journal went so far […]