At last week’s Compliance Week Conference, I saw a paradigm shift in thinking about the factors to be included in a compliance program. Most compliance programs have placed a lot of emphasis on the federal sentencing guidelines. After all, those guidelines give credit for having an effective compliance program. So you want to have an … Read more »
Year: 2009
Enterprise 2.0 at Goodwin Procter
Can law firms jump on the Enterprise 2.0 bandwagon? Lawyers are generally seen as conservative users of technology, preferring to use a quill and inkwell over a web-based publishing platform. David Hobbie shares some of the successes he has encountered in the adoption of Enterprise 2.0 at Goodwin Procter (.pdf – page 13) in the … Read more »
FCPA Visualization
The number of Foreign Corrupt Practices Act charges and the size of the penalties have surged recently. The James Mintz Group pinpointed the location of every bribe that has led to an FCPA case in the last 10 years and illustrated them graphically. The countries that have generated the most FCPA cases in the last … Read more »
Wrap Up of Compliance Week Conference
It was a great few days in Washington D.C. at my first Compliance Week Conference. The conference was packed with great presentations and discussions over its three days. In particular, it was great to spend time with Bruce Carton, Francine McKenna, Scott Cohen, Matty Kelly and Alex Howard. Below are links to some stories from … Read more »
Conversation with Harvey Pitt
This was another “dark session” with about 30 compliance professionals sitting down for an informal discussion with former SEC Chairman Harvey Pitt. I am not going to share detailed notes, just some general issues that were discussed, with no attribution to any individual. Compliance is really about non-compliance. The only reason compliance is relevant is … Read more »
Your Compliance Program and Enforcement
This session at Compliance Week Conference 2009 was another “dark session” so I am not sharing detailed notes, merely a perspective on some issues that were presented. John Roth, an Assistant U.S. Attorney in the Fraud and Corruption Section shared his insights and Bruce Carton did his best Phil Donahue impression by eliciting questions from … Read more »
Compliance Week Keynote from David Ogden
My notes, live, from the keynote address by David Ogden, the Deputy Attorney General. As we confront the current financial crisis and try to restore trust and accountability, we have a shared responsibility to make sure justice is done. Responsible corporate behavior must be encouraged and rewarded. There will continue to enforcement action on financial … Read more »
Structuring Internal Investigations
My notes, live, from the presentation by Neal Stephens and Bill Freeman of Cooley Godward Kronish on the top ten problems and how to avoid them. The focus of the session was to help companies who must conduct an internal investigation avoid pitfalls that add expense, embarrassment and exposure. There are many problems that come … Read more »
Third Party Risks
My notes, live, from Third Party Risks with Matt Tanzer of Tyco International and Chris Nowak of Wyndham Worldwide. For Tyco they have 110,000 employees around the world, most outside the United States. Their first step was to identify all of the third parties. This was a big task. They went to their master vendor … Read more »
McNulty Keynote on a Tale of Two Sectors
My notes, live, from former U.S. Deputy Attorney General Paul McNulty Keynote on A Tale of Two Sectors: The Challenges of Corporate Compliance – When Enforcement Increases and the Economy Declines. Mr. McNulty is now a partner at Baker & McKenzie. He is the author of the McNulty Memo on the government’s perspective on prosecuting … Read more »