Compliance and Ethics Training – How Much is Enough

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

International Standards for the Bribery of Public Officials

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

Evaluation of the Chief Compliance Officer

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.

An Effective Compliance Program under the U.S. Sentencing Commission Guidelines

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

Some Reasons Why Compliance Programs Still Matter

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

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

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

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

FCPA Opinion Procedure Release 94-01

FCPA Opinion Procedure Release 94-01 came from a U.S. company and a foreign citizen. The American company seeks, through its subsidiary, to enter into a contract with a foreign national. The American company’s subsidiary is engaged in the manufacturing of products for use in clinical and hospital laboratories. Its manufacturing operations are located on real