Posts Tagged ‘FCPA’

New Compliance Evaluation Guidelines


The Justice Department released Tuesday a fresh set of guidelines on how prosecutors should evaluate corporate compliance programs: a much longer document, with more narrative explanation about what the Justice Department considers important. Compliance professionals should prepare to obsess over it like last Sunday’s Game of Thrones episode. Assistant attorney general Brian Benczkowski unveiled the…

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More Cognizant FCPA Lessons


Now that we’ve had a long weekend to digest the FCPA enforcement action imposed against Cognizant Technologies last week, compliance officers have a lot more consider here. In many ways what happened with Cognizant is an excellent case-study for corporate ethics and compliance done right, with a few points to ponder about potential risks to…

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$25M to End Cognizant FCPA Case


IT outsourcing firm Cognizant Technologies agreed Friday to pay $25 million in disgorgement and penalties to settle FCPA charges related to bribery in India, while the company’s former president and top legal officer were indicted for their roles in orchestrating the scheme. The settlement included $19 million in disgorgement of ill-gotten profits, plus $6 million…

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Event: Governance Forum, Jan. 23

Next week I have the privilege of moderating an executive forum in Philadelphia, where four stellar thinkers about compliance, audit, and corporate governance will be discussing some of the big issues emerging for executives and board directors in 2019. To focus my thoughts, I’ve been pondering: what are some of the big issues emerging for…

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Nine Compliance Issues for 2019


Welcome to 2019, everyone! The federal government may be shut down, but corporate compliance never stops. Now that we’re done returning Christmas presents and deleting emails clogging our in-boxes, our thoughts turn to how the corporate compliance landscape might evolve in the coming year. Without further delay, then, my annual list of compliance issues that…

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Many Lessons in Polycom FCPA Case


Corporate compliance officers have one more enforcement action to study in 2018: Polycom, the company that makes those UFO-shaped speaker phones on your conference room table. The company (now a subsidiary of Plantronics Corp.) just agreed to pay $36 million to settle FCPA charges in a case with lessons for pretty much everybody. The FCPA…

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More DOJ! New Cooperation Policy


More news from the Justice Department on corporations cooperating with criminal investigations: from now on, prosecutors will only insist that companies identify individuals “substantially” involved with the misconduct in question, rather than everyone involved. So says deputy attorney general Rod Rosenstein, who announced the new policy on Thursday at the annual FCPA Conference happening in…

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DOJ Plugs Cooperation, Compliance

false claims act

All eyes in the compliance community might be the annual FCPA Conference happening in Washington right now, but compliance professionals might also want to note a different speech given across town Wednesday by John Cronan, deputy assistant attorney general. Cronan popped up at a Practising Law Institute event to talk about companies cooperating with law…

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SEC Dings Vantage $5M on FCPA Issues


Texas-based Vantage Drilling International has agreed to pay $5 million in disgorgement to the Securities and Exchange Commission for sloppy FCPA accounting controls that let the company’s largest outside director and various third parties pay bribes to Brazilian government officials in the 2000s. The SEC’s settlement order recounting the failures reads like a long, torturous…

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New DOJ Policy on Compliance Monitors

compliance monitors

The Justice Department dropped a bundle of new policies last Friday about evaluating compliance programs and corporate monitors, with potentially significant implications for corporate compliance officers and the programs you run. Brian Benczkowski, assistant attorney general for the Criminal Division, announced the news during a speech he delivered in New York on Friday. Always be…

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