Auditing and Monitoring in Healthcare
New DOJ Guidance Tightens Corporate Enforcement Strategy
Health Care Continues to Drive False Claims Act Recoveries: Thought Leaders in Health Law Video Series
Accountability: At the Heart of Compliance-Boeing, Part 1-Accountability from Employees
Unfair and Unbalanced-Episode 18
As an accompaniment to our biweekly series on “What Every Multinational Company Should Know About” various international trade, enforcement, and compliance topics, below find an update to our series on compliance checks that...more
"Whistleblowing," a fundamental component of any compliance program, refers to specific allegations of misconduct raised typically through an anonymous hotline or similar mechanism. "Speak-Up" is broader and refers to a...more
We have been getting accountability all wrong in the compliance profession. It's not a set of tasks - it's a way of thinking and it has to come from the heart as well as the head. On Accountability: The Heart of Compliance...more
The MLB Commissioner held senior leadership accountable for illegal sign stealing - even though the conduct generally involved players and low-level operations employees. On January 13, 2020, Major League Baseball (MLB)...more
I recently had the chance to visit with Vincent DiCianni, founder and Chief Executive Officer (CEO), of Affiliated Monitors, Inc. (AMI). (AMI sponsors the podcast series This Week in FCPA). In this conversation, we explored...more
In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more
In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more
On this day 30 years ago, history was made when Spud Webb won the 3rd NBA Slam Dunk contest. Webb joined future Hall-of-Famers Michael Jordan, who won the inaugural contest in 1984, and Dominic Wilkins, who won the second...more
Every company wants to create a culture of ethics. If the senior leadership ignores or downplays a culture of ethics, they have narrowed business opportunities for the company, its shareholders, and other stakeholders. A...more
While naysayers believe the Department Of Justice's (DOJ’s) memo is going to result in major complications and headaches for companies experiencing government investigations, ethical companies are unlikely to be affected much...more
Responding to criticism stemming from a lack of individual prosecutions as a result of the financial crisis, Deputy Attorney General Sally Yates has issued a new guidance memorandum establishing six new steps for federal...more
A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable....more