Bits and Pieces on Compliance

Here are a few stories and items that caught my eye recently, but I have not had time to build-out to a full post: Role of Federal Sentencing Guidelines in FCPA Cases from the WrageBlog Given the tremendous fines imposed upon Siemens AG and Kellogg Brown & Root LLC (“KBR”) in the past 10 months, […]

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Ruehle Decision on Internal Investigations Overturned

The Ninth Circuit stepped into a conflict between former Broadcom CFO William Ruehle and lawyers at Irell & Manella. The disagreement concerned a type of misunderstanding on whether lawyers during an internal company probe are representing a singular executive or the company itself. At issue was whether Irell clearly explained to Ruehle that it was […]

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National Cyber Security Awareness Month

October is National Cyber Security Awareness Month. Check out the top tips to keep you safe online: Know who you’re dealing with online. Keep your web browsers and operating system up to date. Back up important files. Protect your children online. Use security software tools as your first line of defense. Use strong passwords or […]

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Fair Value Accounting: What Lawyers Need to Know

Bruce Carton of Securities Docket put together a great panel of securities and accounting experts to discuss the evolution of fair value accounting regulations and the impact of the guidelines in accounting and legal contexts. Presenters Ray Ball, Professor of Accounting, Univ. of Chicago, Booth School of Business Andy Wong, Analysis Group Michael Young, Willkie […]

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Opportunities Exist to Improve DOD’s Oversight of Contractor Ethics Programs

The Government Accounting Office released a report on the compliance and ethics programs of 57 government contractors each with yearly contracts over $500 million: Defense Contracting Integrity: Opportunities Exist to Improve DOD’s Oversight of Contractor Ethics Programs The report’s survey was conducted in September 2008, before the new Federal Acquisition Regulations were put in place […]

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SEC’s Office of Compliance Inspections and Examinations Gets a Review

The SEC’s Division of Enforcement was not alone in getting a report from the SEC’s Inspector General: Improvements Needed Within the SEC’s Division of Enforcement. The Office of Compliance Inspections and Examinations also got a review from the Inspector General: Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC. For this […]

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Improvements Needed Within the SEC’s Division of Enforcement

The SEC’s Inspector General, H. David Kotz, released his most recent report: Program Improvements Needed Within the SEC’s Division of Enforcement. The report is sort of a follow-up to the Madoff Report. The Office of the Inspector General conducted a review “to identify systemic issues that would prevent Enforcement from accomplishing its mission to enforce […]

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Facebook, Twitter, LinkedIn and Compliance: What Are Companies Doing?

The Society of Corporate Compliance and Ethics and the Health Care Compliance Association conducted a survey among compliance and ethics professionals in late August 2009 to see what employers are doing about the use of these sites by their employees. They got back almost 800 responses from their members using an online survey tool. 50% […]

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Managing Risk in the Financial Sector

On Sept. 16, 2009, Compliance Week and Navigant Consulting presented an exclusive editorial roundtable about compliance practices at financial services firms at The Mandarin Oriental Hotel in Boston. (Apparently not so exclusive, considering I was able to get in. I even made it into one of the article’s pictures. – That’s me eating my fingers […]

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Governing Corporate Compliance and New Governance

Miriam Baer of the Brooklyn Law School published an interesting article on “New Governance”: Governing Corporate Compliance. The professor rejects the notion that adversarial relationships produce good regulation. She looks towards the “theory of regulation characterized by a collaborative tone between regulator and regulated entity, a problem-solving orientation, continuous assessment and revision of both expected […]

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