The Important Distinction Between Ethics and Compliance

I know that I can be a stickler for details sometimes. Ask my children. Ask my wife. So, when it comes… [continue]

The Important Distinction Between Ethics and Compliance The Important Distinction Between Ethics and Compliance

Jodi Arias: Bordering on Death?

Just when we thought Jodi Arias had receded into the shadows of notorious sociopathic killers, she has… [continue]

Jodi Arias:  Bordering on Death? Jodi Arias:  Bordering on Death?

Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official”

With lots of fanfare, Esquenazi and Rodriguez, and the usual suspects filed a cert petition and briefs… [continue]

Knowing When to Fold — Arguing the FCPA’s Definition of  “Foreign Official” Knowing When to Fold -- Arguing the FCPA's Definition of  "Foreign Official"

Prosecution of Chief Compliance Officers: Establishing Basic Professional Standards

We all know that sometimes the press just gets it wrong. They do not understand the nuance of an issue… [continue]

Prosecution of Chief Compliance Officers:  Establishing Basic Professional Standards Prosecution of Chief Compliance Officers:  Establishing Basic Professional Standards

Internal investigations and the Importance of Witness Interviews

Everyone claims to know how to conduct an internal investigation. Given the government’s reliance on… [continue]

Internal investigations and the Importance of Witness Interviews Internal investigations and the Importance of Witness Interviews
Latest Posts

The Important Distinction Between Ethics and Compliance

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I know that I can be a stickler for details sometimes. Ask my children. Ask my wife. So, when it comes to compliance, I repeat myself often when I remind everyone: it is ethics and compliance, not just compliance. Let’s be honest – it is more than mouthful to say … Continue Reading…

Jodi Arias: Bordering on Death?

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Just when we thought Jodi Arias had receded into the shadows of notorious sociopathic killers, she has returned for yet another drama-filled narcissistic replay of her depraved indifference to life and humanity. The Jodi Arias show, Part II, the Sentencing Hearing has begun. Even though there is a blackout of … Continue Reading…

Internal investigations and the Importance of Witness Interviews

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Everyone claims to know how to conduct an internal investigation. Given the government’s reliance on internal investigations, law firms have beefed up their internal investigation services. Inevitably, the quality of internal investigations will be mixed. Internal investigations can cost lots of money, especially when conducting a global investigation. Avon and … Continue Reading…

China and Antitrust Enforcement

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China’s entry into the anti-corruption enforcement arena has received lots of press attention. Just as significant as this development, China has added international cartel enforcement to its list of priorities. With far less fanfare, China has found “religion” when it comes to prosecuting price fixing conduct. China’s National Development and … Continue Reading…

Supply Chain Management: Avoiding Headaches

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Companies implementing due diligence programs face a number of challenges. It is hard enough to identify all of a company’s third-party intermediaries – agents, distributors, customs and logistics representatives, nominees, and professionals, just to name a few. Getting your arms around these third parties to make sure they are subject … Continue Reading…

Goodbye Mr. Millikin: GM’s Continuing Culture Challenges

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The GM debacle over its handling of the ignition switch defect continues. GM’s CEO Mary Barra and the rest of GM’s leadership just do not seem to be getting the message. It is not unusual for C-Suite executives to lead from an ivory tower. In the face of a dramatic … Continue Reading…

Higher Education Compliance and the Scourge of Campus Sexual Assaults

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Chief Compliance Officers who lament the challenges of their jobs should be thankful they are not in charge of compliance for higher education institutions. The culture of compliance has extended into many high-risk areas but one area where compliance is catching up is higher education. Universities and colleges face a … Continue Reading…

Look What DOJ Found – A New Enforcement Tool: FIRREA

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The Justice Department recently read through the United States Code and discovered something important — a statute that authorizes the government to issue administrative subpoenas to build massive civil fraud cases that carry huge penalties. For some reason, the Justice Department never used the statute until recently as a weapon … Continue Reading…