Posts Tagged ‘Investigations’
‘Owning the Risk’ and Compliance
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…
Read MoreImportant Case on 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…
Read MoreActivision Clears Self of Misconduct
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…
Read MoreWhen Is an Investigation ‘Joint,’ Anyway?
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…
Read MoreInvestigations, Governance, and Romance
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…
Read MoreTwo Insights on 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…
Read MoreHomecoming: Best New Show Starring Compliance
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…
Read MoreKavanaugh and Compliance, Part II
Exactly one week ago, all we knew about Brett Kavanaugh’s personal conduct was that one woman had accused him of sexual assault 35 years ago when they were both high school students; and that Kavanaugh denied the allegations. Well, a lot can change in one week. Today we have a broader collection of allegations against…
Read MoreThe Kavanaugh Compliance Lessons
Now that Brett Kavanaugh’s nomination to the Supreme Court has turned into a #MeToo meltdown, ethics and compliance officers should roll up their sleeves. Peel away the political dimension to this mess, and plenty of lessons emerge about investigations, whistleblower reports, and corporate values that are worth contemplating. We have several threads to pull: how…
Read MoreEthics and Firing David Shulkin
We should never underestimate the Trump Administration’s ability to snatch defeat from the jaws of ethical victory. That certainly seems to be the case with last week’s firing of David Shulkin, now former secretary of Veterans Affairs. Compliance officers in the corporate realm should take note, so your CEO doesn’t shoot your ethics program in…
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