Here are some interesting compliance, risk and ethics stories from the past week: Robert Kennedy, the Travel Act and the FCPA by Thomas Fox in Tfoxlaw’s Blog Robert Kennedy’s contribution is that while Attorney General, he urged Congress to enact the Travel Act in 1961 which was passed as part of the same series of [...]
Archive | January, 2010
New Social Media Policies Database
I assembled a collection of social media policies: Social Media Policies Database. So far I have 117 a bunch in the database. That’s a very small number, but I think most companies want to keep their policies private. If I am missing any, please leave a comment letting me or send me an email: compliancebuilding@gmail.com. [...]
Questions and Answers with Robert Khuzami
After the news conference announcing the Rearrangement of its Enforcement Program, the Securities and Exchange Commission offered a group of bloggers the chance to ask questions to Robert Khuzami, the Director of Enforcement. (It must have felt like Obi-Wan stepping into the cantina full of low-life scoundrels.) The blogging participants: Todd Sullivan of Value Plays [...]
SEC Rearranges its Enforcement Program
The Securities and Exchange Commission reorganized its enforcement division. Enforcement Director Robert Khuzami announced a new program announced the creation of new units. First, the SEC are expanding the whisteblower program. They are calling it a “cooperation program.” Then there are five new units in the enforcement division. Asset Management Unit The unit specializing in [...]
SEC News Conference on its Enforcement Program
Bruce Carton of Securities Docket, Francine McKenna of Re: The Auditors and I are attending the SEC’s news conference virtually and taking notes using the CoverItLive tool embedded below. SEC Enforcement News Conference
Ethics of Congressional Stock Ownership
The Washington Post published a story using Congressman John Dinghell as an example of the ethics issues involved when you have an investor lawmaker: Dingells and GM illustrate limits of congressional conflict-of-interest rules. Kimberly Kindy and Robert E. O’Harrow Jr. use Congressman Dinghell because of his financial connection with General Motors. This connection was one [...]
SUPERfreakonomics and Compliance
Steven D. Levitt and Stephen J. Dubner are back putting the freak in economics. As they did in Freakonomics, SUPERfreakonomics uses economic analysis to give some insights into actual human behavior. When the original Freakonomics came out it was very original. Since then other books have hit the mainstream trying to do the same thing, [...]
FinCEN and Address Confidentiality Programs
How do you open a bank account when you are hiding from domestic violence? The rules implementing the Bank Secrecy Act require a financial institution to implement a Customer Identification Program that includes procedures that enable it to form a reasonable belief that it knows the true identity of its customers. The rules also require [...]
Ethics of Oreos in the Minibar
Is it ethical to replenish the items in your hotel’s minibar to avoid being charged for consumption? Randy Cohen tackled this issue in last week’s The Ethicist. David Lat, publisher of the legal tabloid Above the Law, posed the question after eating a box of Oreos from his minibar and then later replacing them. Mr. [...]
Monitoring Employee E-mail in Canada
The key to a defensible system of e-mail monitoring is the creation of a comprehensive and communicated computer use policy. That is apparently as true in Canada as it in the United States. Brian Bowman and Andrew Buck put together an excellent privacy primer on Monitoring employee e-mail: a privacy primer. In what situations is [...]
Social Media
My social media policies database is available to you.
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