Compliance Bricks and Mortar for March 21


Welcome to Spring.

These are some of the recent compliance-related stories that recently caught my attention.

Two Thoughts about Dewey LeBoeuf and Parallel Proceedings by David Smyth in Cady Bar the Door

In a devastating New York Times story over the weekend, James Stewart zeroed in on that last sentence.  Client relations manager?  Who? Apparently it wasn’t obvious to “longtime Dewey insiders”who Zachary Warren even is.

Warren graduated from Stanford in 2006, and applied to be a Dewey paralegal.  “Instead, he was offered a $40,000-a-year job helping partners collect client debts.

NEWSFLASH: Common sense prevails again! Prosecutors give credit for compliance programs in Norway too. in the Bribery Act .com

Today Barry spoke at the Oslo Compliance Forumorganized by Wiersholm, Norway’s largest law firm which itself has a history of advising and representing clients on anti-corruption compliance and investigations.  I spoke at length to Jan FougnerMarit Berger Rosland and Georg Engebretsen – they know what they’re talking about and have been involved in some big cases – so if you have a problem in Norway, call them.  I would in a heartbeat.

SEC Discourages Incentivizing Whistleblowers to Keep Complaints In-House by Christopher M. Varano in Fox Rothschild’s Securities Compliance Sentinel

What’s good for the goose is apparently not so good for the gander, as the SEC warns in-house attorneys against whistleblower contracts.

The Cost of Compliance by Michael Volkov in Corruption, Crime & Compliance

The title for this posting is a little ambiguous.  What is the “cost” of compliance?  Is it the cost of implementing an “effective” compliance program?  Or is the “cost” to the company of an “ineffective” compliance program.  Let’s just say it is both.