FCPA Compliance Report

The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is...

2 Mars 201711min

One event which promises to be most excellent is the upcoming Third-Party Risk Management & Oversight Summit, on March 20 & 21 at the Princeton Club in New York City. I will be attending and speaking ...

2 Mars 201717min

Last month, the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), on the Fraud Section website. The document is an 11-p...

1 Mars 201710min

In this episode Matt Kelly and myself take a deep dive into SOX 404(b), what it requires and how companies comply with the reporting requirements set out in this statute. We consider the recent announ...

1 Mars 201722min

I end my One Month to a Better Board series with a discussion from the recently released Justice Department Evaluation of Corporate Compliance Programs as it relates to a Board of Directors. In an are...

28 Feb 201712min

This podcast considers the differences between forecasting and risk assessment is that risk assessment attempts to consider things which forecasting either did not reliably predict for, or those thing...

28 Feb 201721min

There are three core areas upon which Directors should focus their attention regarding to help establish and maintain an effective compliance program. They are: (1) structure, (2) culture and (3) risk...

27 Feb 201713min

Where does “Tone at the Top” start. With any public and most private US companies, it is at the Board of Directors. But what is the role of a company’s Board in FCPA compliance? We start with several ...

24 Feb 201713min