Dealing With Kirk Accusations

allegation

Compliance officers might be hoping to avoid the vicious political fallout from the assassination of right-wing provocateur Charlie Kirk. Well, no such luck: online activists are now trying to out supposed anti-Kirk critics, sometimes getting it wrong, and heaping a pile of investigative and due process headache onto your doorstep.  The headache happens as follows.…

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On Navigating Global Legal Tensions

Global

One big challenge for compliance officers is how to manage your program at a global level, when so often that means juggling multiple legal jurisdictions with conflicting standards for corporate behavior. So when I had the chance recently to moderate a webinar on that very subject, I took lots of notes. I pass them along…

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Compliance Programs and Leaks

leaks

This week I’m in Portugal at the Society of Corporate Compliance & Ethics’ annual European conference, where I attended an excellent discussion on the ethics and compliance challenges of employees leaking confidential matters outside the business. So in the spirit of leaks, I took lots of notes and now pass them along to you. Compliance…

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‘Owning the Risk’ and Compliance

risk

Compliance officers and regulators alike always love to say “the business owns the risk” — and we all know that here in the real world, those words often fall short of reality. I recently had a conversation with a compliance officer friend that reminded me just how widespread that shortcoming is. With his permission, I…

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Important Case on Investigations

investigations

An important update from the world of internal investigations: a federal judge has ruled against two former executives of Cognizant Technologies, who had been arguing that Cognizant had acted as a de facto arm of the government when the company investigated the two about their role in a corruption scheme.  The ruling came down from…

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Activision Clears Self of Misconduct

Activision

Activision Blizzard published the results of an internal investigation today that found “no widespread harassment” at the videogame giant from 2016 to 2021, despite a lawsuit from California regulators last year alleging exactly that and massive turmoil among Activision employees since then. The investigation was ordered by Activision’s board last year after the California Department…

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When Is an Investigation ‘Joint,’ Anyway?

investigations

All you criminal procedure mavens out there might be interested in a ruling from a federal district court in New Jersey this week, where two business executives facing FCPA charges were quibbling over whether the Justice Department and the SEC conducted a “joint” investigation into their alleged crimes.  Apparently that question matters because the defendants…

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Investigations, Governance, and Romance

investigations

Heartbreaker of a tale unfolding at the Romance Writers of America this week: a misconduct complaint filed against the head of the RWA’s ethics committee has backfired, leading to a revolt of the group’s membership, half the board resigning in protest, and the organization’s flagship event canceled for 2020.  Ethics and compliance professionals should give…

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Two Insights on Investigations

investigations

On Wednesday I had the privilege of moderating an executive forum in Philadelphia on corporate governance and investigations. Roughly 40 compliance and audit executives were there, hosted by audit firm Baker Tilly and law firm Morgan Lewis. Our goal: hash out some of the current challenges in managing complex investigations. Granted, you could talk about…

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Homecoming: Best New Show Starring Compliance

Carrasco

Compliance and audit professionals can rejoice at yet another pop TV show that captures what you do so brilliantly: Homecoming, a stripped-down, fast-paced drama on Amazon where the action rests on the shoulders of a Defense Department compliance officer. The stars of the show are Julia Roberts, who plays troubled social worker Heidi; and Bobby…

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