FCPA Compliance Report

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior managem...

9 Jun 201713min

In an article in the Corporate Board magazine, entitled “Successful Board Investigations” by David Bayless and Tammy Albarrán, partners in the law firm of Covington & Burling LLP posited seven conside...

8 Jun 201710min

The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords the same week the Astros a...

8 Jun 20171h 7min

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigo...

7 Jun 201711min

In the case of Kokesh v. SEC, the US Supreme Court held the profit disgorgements operate as a penalty under the Securities and Exchange Act of 1934, as amended. As such “any claim for disgorgement in ...

7 Jun 201718min

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based on...

6 Jun 201711min

In this episode, I visit with Chris Morton, the SVP, Marketing and Corporate Development for Navex, about the firm's new resource for the Compliance Community, ComplianceNext.com. It is a free, compli...

6 Jun 201722min

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could i...

5 Jun 201711min