FCPA Compliance Report

The Department of Justice Evaluation of Corporate Compliance Programs states, in Prong 10, Third Party Relationships:  Management of Relationships – How has the company considered and analyzed the th...

24 Mar 201713min

The Evaluation, in Prong 10, Third Part Management asks, “What was the business rationale for the use of the third party in question?” This question is one of the most basic tools to operationalize yo...

23 Mar 201711min

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Jay Rosen and Jonathan Armstrong provide next insigh...

23 Mar 201739min

From the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs:  Autonomy and Resources  Stature – How has the compliance function compared with other strategic functions in th...

22 Mar 201714min

In this episode I visit with Susan Divers from LRN on the firm's 2016 Ethics and Compliance Program Effectiveness Report. Highlights include:Why did LRN do the report? What did it hope to determine? A...

22 Mar 201726min

Prong 6, Training and Communication, of the Justice Department’s Evaluation of Corporate Compliance Programs reads, in part:  Form/Content/Effectiveness of Training – Has the training been offered in...

21 Mar 201714min

In this inaugural episode of the FCPA Compliance Report-International Edition, I have Carlos Ayres, a partner in Madea, Ayres and Sarubbi in Sao Paulo. We discuss an  interesting development from the ...

21 Mar 201724min

The Justice Department Evaluation of Corporate Compliance Programs states the following around training: Training and Communications Risk-Based Training – What training have employees in relevant ...

20 Mar 201712min