Lots of hallway conversations have turned into email and instant messaging conversations. There are lots of problems with that. First, is just the lack of human interaction. Humans are social and need to meet face-to-face. Along with that is the limited ability to add tone, sarcasm and other elements of conversation into the written word.
In this podcast panel discussion, OCEG’s Carole Switzer moderates a discussion with ELT’s Shanti Atkins and SAI Global’s Mark Rowe to answer the question of how much is enough when it comes to compliance and ethics training. You can listen to a webcast and read a transcript (.pdf). Ms. Atkins talks about a three layers
The Fall 2006 Issue of Cadwalader’s FCPA Advisor provides a great background and overview of the Foreign Corrupt Practices Act.
The Foreign Corrupt Practices Act is the U.S. standard for bribery of public officials by U.S. concerns or international concerns with a presence in the U.S. The international standard is the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions promulgated by the Organization for Economic Co-Operation and Development. The convention sets
Thompson Hine put together a paper: Evaluation of the Chief Compliance Officer: While Rule 38a-1 under the Investment Company Act requires a Board of Directors to approve the appointment, removal and compensation of a fund’s Chief Compliance Officer (“CCO”), the rule is silent as to any requirement to annually review the performance of the CCO.
Section 8B2.1 of the 2007 version of the United States Sentencing Commission Guidelines define and “effective compliance and ethics program” for purposes of section (f) of § 8C2.5 for the Culpability Score and section (c)(1) of §8D1.4 for Recommended Conditions of Probation – Organizations: (a) To have an effective compliance and ethics program, for purposes
Sharie A. Brown of Foley & Lardner LLP, wrote U.S. Foreign Corrupt Practices Act for the August 2008 of Compliance Week and put forth five very good reasons why your anti-corruption compliance program still matters a lot. Effective programs mitigate fines and penalties Early detection allows early company solutions Trust is valuable Good controls help
FCPA Review Procedure Release 81-02 came from the Iowa Beef Packers, Inc. who wanted to send promotional samples to the Soviet Ministry of Foreign Trade, the Soviet government agency responsible for procurement of such products. The total amount of the samples which the company intends to furnish to these officials is approximately 700 pounds of
FCPA Opinion Procedure Release 93-01 came from a company planning to enter into a joint venture partnership agreement to supply management services to a business venture owned and operated by a quasi-commercial entity, which entity is wholly owned and supervised by the government of a former Eastern bloc country. The requestor has represented that although
FCPA Opinion Procedure Release 93-02 came from a company which seeks to enter into a sales agreement with an entity in a foreign country. The entity is a government-owned business which holds a licence giving it the exclusive right to manufacture, sell, purchase, import, and export all defense equipment for that country’s armed forces. The