Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance into the Weeds: Of Fat Fingers, Internal Controls and Compliance
Vicky Hanks of Blake Morgan on Building an Effective Employee Brand - Passle's CMO Series Podcast
Better Investigative Interviewing
Hot Topics in International Trade
Episode 301 -- Steve Naughton on Compliance and Complaince Education at Loyola Law School Program
Episode 298 -- Electronics Communications Risks and Ephemeral Messaging
Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
JONES DAY TALKS®: The Evolution of Corporate Compliance Programs: Key Issues for Multinational Companies
Compliance & Disaster Preparedness
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
Law Firm ILN-telligence Podcast: Episode 73: Daniel García Piñeros, Gamboa, García & Cardona Abogados
Episode 284 -- How to Implement a Compliance Compensation System
Episode 276 -- Review of Phillips and Franks Int'l SEC FCPA Settlements
One Month to More Effective Internal Controls - Day 17 - COSO Objective IV: Information and Communication
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more
On March 14, 2023, DXC Technology Company (“DXC”) settled with the Securities and Exchange Commission (“SEC”) for $8 million regarding alleged misleading disclosures in DXC’s public filings. The SEC claimed DXC made...more
What happened? In a recent settlement order, the SEC charged Activision Blizzard with failing to maintain adequate disclosure controls and procedures. Notably, the SEC did not claim that the company’s SEC filings were...more
Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records. As everyone knows, these provisions can be applied to a wide-range of...more
The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more
On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more
On June 15, 2021, the SEC announced that it had settled charges against First American Financial Corporation for failures in First American’s disclosure controls and procedures. Rule 13a-15(a) under the Exchange Act requires...more
Mortgage Company to Pay $24.9 Million to Resolve Alleged False Claims Act Violations - On October 28, 2020, the Department of Justice (the “DOJ”) announced that Guild Mortgage Company (“Guild”), a California-based...more
Possible settlement in class action involving ARA and stockholders - The U.S. District Court for the District of New Jersey will consider a proposed settlement of class action case involving individuals who purchased...more
This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more
At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more
DOJ settlement signals need for enhanced False Claims Act scrutiny. Private funds continue to face heightened secondary liability risks arising from their portfolio investments....more
On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more
This newsletter discusses noteworthy updates, key regulatory decisions and upcoming compliance reminders. ...more
June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more
On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
On September 28, 2018, the Securities and Exchange Commission (“SEC”) announced a settlement with a Michigan-based manufacturer and distributor of medical devices, over allegations that the company had violated the books and...more
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more
Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more
Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more