Tag Archives: compliance

Board Engagement: The Ethics and Compliance Missing Link

It’s been a year since I wrote about The Board’s Overlooked Role in Compliance. At the time, it seemed that momentum was building for more proactive board engagement in establishing and overseeing compliance programs. After all, regulators and courts have been increasingly outspoken about the importance of effective compliance programs and pointed about the essential … Continue Reading

The ICE-Man Cometh: How to Avoid Becoming the Next Immigration Raid Headline

Last October, Thomas Homan, the acting director of Immigration and Customs Enforcement (ICE), announced that 2018 would see a significant increase in worksite related investigations. He pledged a four-fold increase in worksite audits. This seems unsurprising given the Trump campaign and subsequent Trump administration’s focus on reducing or ending illegal immigration to the United States. … Continue Reading

Rise Above ‘Why Compliance Programs Fail’ With Behavioral-Based Tips

I recently cracked open my Harvard Business Review to the article on “Why Compliance Programs Fail.” I read with great interest the authors’ theory on how weak, milque-toast metrics can result in check-the-box, paper-only compliance programs. I don’t disagree at all, but I have a few practical suggestions to add. The authors cite, as have … Continue Reading

In Light of the Brand Memo, Has the Way of Compliance Gone by the Wayside?

After then-U.S. Associate Attorney General Rachel Brand issued a memorandum (known as the “Brand Memo“) in January 2018, which some have interpreted as recanting all reliance on DOJ guidance documents, what’s next? Call me Pollyanna, but I contend that “the way of compliance” is here for good. Pun intended. First, annual survey results list compliance matters as … Continue Reading

The U.S. Justice Department’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised corporate enforcement policy for the Foreign Corrupt Practices Act. The revised policy is based on an FCPA pilot program (in place since April 2016), which provided mitigation credit for voluntary reporting of wrongdoing and specified levels of cooperation and remediation in connection … Continue Reading

Updated U.S. Civil Penalties Raise the Cost of Noncompliance

In 2016, we let you know about the redundantly titled “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” which required that heads of government agencies adjust civil penalties yearly to account for inflation. Announcements must take place by July 1 of each year. As a result, most federal agencies have announced their 2017 … Continue Reading
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