The Redcoats are coming! The Redcoats are coming! Patriots’ Day is a Massachusetts state holiday commemorating the opening battles of the American Revolutionary War in Lexington and Concord in April, 1775. In the morning there is a battle reenactment on the Lexington Green of the early-morning engagement between the town’s militia and the British regulars. [...]
Archive | April, 2009
Quick Hits
Some quick hits on stories that interest me, but did not make it to a full post: SEC Posts XBRL Compliance Guide from The Filing Cabinet by Melissa Klein Aguilar The staff of the Securities and Exchange Commission has posted a “small entity compliance guide” on its rules that require companies to submit financial statements [...]
Corresponding with Cornelius
Here are some of my recent comments on some other blogs or other websites that allow comments. I am happy to have you leave comments at Compliance Building. But if not here, take a look at what other people are saying. Join me in the conversation over there. What Would You Do?? by Heather Milligan [...]
Risk Assessment – Getting It Right
PricewaterhouseCoopers LLP sponsored this webcast: Corporate leaders have long recognized that the pace of change continues to increase in velocity, thus challenging management’s execution of the business’ strategic and tactical plans. Enterprise Risk Management (ERM) is a management tool that can be effective in identifying and assessing the risks that come with change and allow [...]
Corporate Miranda for Internal Company Investigations
As in-house counsel are often the ones starting an internal investigation, they need to be mindful of the same issues that appear when outside counsel are conducting an internal investigation. I wrote about the referral for discipline in the Ruehle case and the malpractice claim in Pendergast-Holt investigation in Attorney-Client Privilege and Internal Investigations. It [...]
Dishonest Deed, Clear Conscience
In the world of compliance, you may sometimes wonder if that code of ethics really works. Lisa L. Shu, Francesca Gino, and Max H. Bazerman presented their research that a code of ethics really can reduce bad behavior: Dishonest Deed, Clear Conscience: Self-Preservation through Moral Disengagement and Motivated Forgetting. Their studies provided evidence that morality [...]
It’s Tax Day – Are You Tempted to Cheat on Your Taxes?
The American tax system is a good test case for cheating. We know it’s good to pay taxes because the government does lots of good things for us. At the same time, we have a selfish desire to pay as little in taxes as possible. Our tax returns are self-reporting for our income and characterization [...]
The Impersonator – How Attorney Marc Dreier Bilked Investors Out of Millions
We live in an age of white-collar villains. But of all the financial bad guys out there, Marc Dreier is arguably the single greatest character of them all. Bernie Madoff may have stolen more money. Dick Fuld may have caused more systemic damage. But it’s Dreier alone whose story reads like the stuff of Hollywood. [...]
Money Laundering with a Washing Machine
What better way to launder money than with an actual washing machine? Law enforcement in Dover, England broke up an international money laundering racket. They found £600,000 stuffed inside a washing machine that had come from the Port of Dover. Money Laundering by Simon Hughes in The Sun
Red Book 2.0 Released by OCEG with the GRC Capability Model
The Open Compliance and Ethics Group has released the second version of its Red Book about compliance models. OCEG’s Red Book 2.0 provides a guide for implementing and managing a GRC system or aspect of that system. That means Governance, Risk, and Compliance. Red Book 1, which came out in 2005, focused on “getting the [...]
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