Effective ethics laws, in Virginia and elsewhere, depend on enforcement through prosecution, independent ethics review boards, ethics training, and transparency and openness in government. In other words, Virginia will have to do more than change a few gift laws currently under review.
Entries in conflicts of interest (8)
On Thursday, the Financial Industry Regulatory Authority (FINRA) released its 2014 Regulatory and Examination Priorities letter to help firms review and enhance their compliance programs. FINRA emphasized that it will be examining for strong controls and compliance efforts in the areas covered in the letter, as they were deemed to pose significant risk to investors and the integrity of the market as a whole.
When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work.
We've been talking about codes of conduct for compliance officers. But let's face it. At too many companies, the true code is simple: Please Your Boss. The conflict resolution principle is Go Along to Get Along. In practice, at these companies compliance is subservient to the power and prerogatives of top management.
It's that time of year again. Across the country, law students are thinking about paper topics for seminar courses and journal notes. Like last year, I am posting a list of resources that I provide to students every fall in the Anti-Corruption seminar that I co-teach with my colleague, Professor Chris Yukins.
A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.
Oil field services giant Halliburton said this week its internal investigations into potential FCPA and conflict violations in Angola and Iraq are continuing, and the company is reporting all results to the DOJ and SEC.