Compliance Bits and Pieces for June 18

Here are some recent stories that I found interesting:

Who Does Your Chief Compliance Officer Report To? by Thomas Fox in a guest post on The FCPA Blog

Should a CCO report to a company’s Board of Directors, or an appropriate Board committee such as an Audit Committee or Compliance Committee? Or can a CCO report to a company’s General Counsel (GC) but have access to the Board of Directors for periodic, but no less than annual, reporting? Is there any specific guidance from the Foreign Corrupt Practices Act (FCPA) or any of its U.S. government interpretations such as the U.S. Sentencing Guidelines? Is one approach more preferable than the other?

The Ethics of Perception vs. Reality by Kathleen Edmond, Best Buy’s Chief Ethics Officer

Is it OK for our employees to engage company vendors in private contracts unrelated to their work on behalf of Best Buy? Why or why not?

Why Congressional Insider Trading is so Profitable in

In my paper, The Stop Trading on Congressional Knowledge Act, I explained that a 2004 study of the results of stock trading by United States Senators during the 1990s found that that senators on average beat the market by 12% a year. In sharp contrast, U.S. households on average underperformed the market by 1.4% a year and even corporate insiders on average beat the market by only about 6% a year during that period. A reasonable inference is that some Senators had access to – and were using – material nonpublic information about the companies in whose stock they trade.

Congressman attacks student videographer on public street by Carlos Miller in Photography is Not a Crime

Bob Etheridge, a Democratic Congressman from North Carolina was walking down the street in Washington DC when he was asked a simple question by a student videographer “Do you fully support the Obama agenda?” The Congressman got irate and began demanding “who are you? who are you?” He then took a swing at the student before grabbing his wrist.

BP: Still not as evil as Goldman Sachs by Felix Salmon