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Securities and Exchange Commission (SEC) Risk Management Internal Investigations

Thomas Fox - Compliance Evangelist

Internal Reporting and Investigative Lessons from Star Trek: The Conscience of the King

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Fisher Phillips

Top 20 Questions to Ensure Your Compliance Program Helps You Minimize Corporate Criminal Risks

Fisher Phillips on

Among the most critical developments companies and their counsel should understand in 2023 is that federal officials will now scrutinize the overall state of your compliance program when they consider potential criminal...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

Thomas Fox - Compliance Evangelist

From the Code of Conduct to Risk Assessment to Continuous Improvement

How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC v. RPM International — A Cautionary Case Study on the Limits of Attorney-Client Privilege and Work-Product Protection

While much of the corporate legal world has been focused on the effects of the COVID-19 pandemic, a little-noticed case working its way through the federal courts in Washington, D.C. threatens to whittle down the scope of...more

Thomas Fox - Compliance Evangelist

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Thomas Fox - Compliance Evangelist

Farewell to The Hawk – Fair and Consistent Application of Discipline

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

WilmerHale

SEC Applies Whistleblower Interference Rule to Corporate Confidentiality Requirement

WilmerHale on

On April 1, the US Securities and Exchange Commission issued—in a settled administrative proceeding—a cease-and-desist order in In the Matter of KBR, Inc., directing that the respondent cease violating Commission Rule...more

Latham & Watkins LLP

Three Practical Steps to Managing FCPA & Anti-Corruption Risks

Latham & Watkins LLP on

Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively...more

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