Episode 66 -- Gifts and Hospitality Compliance and Best Practices
Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more
In today’s heightened enforcement environment, compliance auditing isn’t just a best practice—it’s a necessity. Federal and state laws and industry guidance, including the Office of Inspector General (OIG) Compliance Program...more
Companies should identify and, where appropriate, manage risk associated with gifts and entertainment by incorporating a clear policy into their overall corporate compliance strategy. On September 11, 2020, the French...more
How is the new generation of policy automation management solutions changing the game and solving policy management’s thorniest problems? ...more
In a number of enforcement contexts, I am always struck by a common theme – crooks are able to obtain access to corporate money for improper purposes. You never hear about a crook who uses his own money to pay bribes or...more
I have finished up my week in Brazil and I wanted to end this week’s Brazil focused blog posts with some final thoughts and observations on the country’s burgeoning compliance scene....more
My challenge on when to write about the Indians winning streak informs today’s blog post, as I consider when you should use ongoing monitoring. Every compliance practitioner recognizes the prevent, find and fix tripartite...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more