Marubeni: FCPA Repeat Offender

In this era of aggressive FCPA enforcement, there are critics who have suggested that the Department… [continue]

Marubeni:  FCPA Repeat Offender Marubeni:  FCPA Repeat Offender

Ignoring the Compliance Message

Companies that ignore the need for an ethics and compliance program deserve whatever they get. There,… [continue]

Ignoring the Compliance Message Ignoring the Compliance Message

Risk Planning and Board Liability

Board members are in the hot seat, or to put it another way – they are in a hot kitchen. The question… [continue]

Risk Planning and Board Liability Risk Planning and Board Liability

Prosecuting Compliance “Gatekeepers”

Every organization depends on persons who are in a unique position to identify potential problems before… [continue]

Prosecuting Compliance “Gatekeepers” Prosecuting Compliance “Gatekeepers”

Putting the Ethics Back into Healthcare Compliance

We all know someone who is a pest, a professional colleague, a friend or even a family member. I use… [continue]

Putting the Ethics Back into Healthcare Compliance Putting the Ethics Back into Healthcare Compliance
Latest Posts

Marubeni: FCPA Repeat Offender

marubeni

In this era of aggressive FCPA enforcement, there are critics who have suggested that the Department of Justice should concentrate its prosecutions on individuals rather than imposing ever-increasing criminal fines on corporations. These critics claim that individual criminal prosecutions are the most effective means to deter criminal conduct. The Justice … Continue Reading…

Ignoring the Compliance Message

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Companies that ignore the need for an ethics and compliance program deserve whatever they get. There, I said it. Chalk up another profound grasp of the obvious. The latest PWC Survey on the State of Compliance (here) noted two significant results: Size of Company Percentage with No CCO/Head of Compliance … Continue Reading…

Risk Planning and Board Liability

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Board members are in the hot seat, or to put it another way – they are in a hot kitchen. The question is whether they can stand the heat of the hot kitchen. Plaintiff’s lawyers are out in full force these days, ready to sue any company board when a … Continue Reading…

Prosecuting Compliance “Gatekeepers”

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Every organization depends on persons who are in a unique position to identify potential problems before they occur. Companies depend on gatekeepers to disrupt and prevent potential misconduct. Internal and external auditors, compliance officers, in-house and outside legal counsel, senior executives and even board members can play this role. In … Continue Reading…

Putting the Ethics Back into Healthcare Compliance

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We all know someone who is a pest, a professional colleague, a friend or even a family member. I use the term affectionately and especially when I write postings that are restatements of obvious points. In the healthcare compliance field, it is striking how compliance is often defined by only … Continue Reading…

CCOs Take Note: It’s the Culture Stupid

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If CCOs are really ready to take the reins and assume a real role in the C-Suite, they need to develop more mature measurements and reports for senior management and the board of directors. We have all seen the color-coded reports with bar charts on numbers and types of complaints … Continue Reading…

Improving Corporate Board Performance: Self-Evaluations

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If CEOs and senior managers are being asked to increase their commitment to ethics and compliance, and if mid-level managers and employees are being asked to increase their commitment to ethics and compliance, then it is time for corporate boards to step up and commit to improving corporate governance, and … Continue Reading…

HIPAA Data Breaches

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HIPAA has been on the books since 1996. With the advent of electronic health records, HHS adopted security regulations to require covered entities to protect the integrity, confidentiality, and availability of electronic personal health information (PHI). The Security Rule was adopted in 2003 and includes data breach notification requirements. The … Continue Reading…

CCOs Need a Seat at the Table

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Chief Compliance Officers are moving up  the corporate ladder. They are being separated out of the legal function and empowered to exercise greater authority in the company. Research already has shown that this structure makes a company’s ethics and compliance program more effective. The next challenge facing CCOs is to … Continue Reading…