Today let’s return to some issues raised during last week’s ACI conference about FCPA enforcement. Speakers offered a few examples of when the Justice Department might still press for vigorous prosecution (rather than a straightforward declination), and compliance officers have much to consider here. For starters, let’s remember that the Justice Department announced new, more…
The United Kingdom has unveiled its new national anti-corruption strategy, a five-year plan sure to warm the hearts of ethics and compliance professionals everywhere. It includes plans such as financial rewards for whistleblowers, faster investigation of corruption cases, and more international cooperation to fight bribery; although how much of this will actually come to pass…
Compliance audits are part of life for corporate compliance professionals: planning the audit, making sure it stays on schedule, working well with business units undergoing the audit to be sure nothing goes haywire. Last week I had the good fortune to moderate a webinar on compliance audits and took lots of notes. Let’s review. First,…
The Compliance Jobs Report is back! We’re working through a holiday backlog this week, with news from Walmart, Bristol Myers Squibb, Caltech, Uber, American Express, Fannie Mae, and so many more. Job leads are in payroll, natural gas, and furniture; and Meme of the Week goes out to Joey from ‘Friends!’ We also take any…
Deputy attorney general Todd Blanche gave a high-profile speech to corporate compliance professionals on Thursday — but really, should we care? Because Blanche’s boss in the Oval Office is pardoning fraudsters so fast and furious these days that you can’t trust anything Blanche proclaims as policy. For the record, Blanche delivered a keynote address Thursday…
The Justice Department is launching a charm offensive with the FCPA compliance community this week, telling compliance professionals at a conference in Washington today that enforcement is returning to “more of the traditional cadence” and we can expect to see more enforcement actions next year. Whether anyone believes those words is another matter, and we’ll…
The Federal Trade Commission is ordering an education technology vendor to adopt a new data security program after a massive data breach in 2022. No monetary penalties involved, but for cybersecurity and privacy professionals looking for the latest enforcement messages from the Trump Administration, this one is worth studying. The company in question is Illuminate…
Compliance professionals have one more issue to consider from that FCPA enforcement action last month against Millicom for corruption in Guatemala. Let’s look at what the case can tell us about the tug of war between lucrative business potential and corruption risk. This has been on my mind since the Justice Department reached the settlement…
Good news for compliance officers looking for an excuse to avoid awkward family conversation at Thanksgiving: the U.K. Serious Fraud Office just issued new guidance on when and how the agency will evaluate corporate compliance programs. The SFO issued the guidance on Wednesday. It outlines six scenarios where SFO prosecutors might decide they need to…
An advisory committee to the Securities and Exchange Commission will meet next week to consider whether publicly traded companies should be required to disclose more about artificial intelligence, such as whether boards have formal oversight of AI and what the company believes its material AI risks are. The proposals come from the SEC Investor Advisory…
