Day 7 of One Month to Better Investigations and Reporting
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 Juni 201713min
Day 6 of One Month to Better Investigations and Reporting
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 Juni 201710min
Everything Compliance-Episode 12
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 Juni 20171h 7min
Day 5 of One Month to Better Investigations and Reporting
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 Juni 201711min
FCPA Compliance Report-Episode 332
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 Juni 201718min
Day 4 of One Month to Better Investigations and Reporting
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 Juni 201711min
FCPA Compliance Report-Episode 331, Chris Morton
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 Juni 201722min
Day 3 of One Month to Better Investigations and Reporting
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 Juni 201711min
