Entries in Effective Compliance Program (121)
Assistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.
The DOJ and SEC haven't used the word "scalable" to describe an effective compliance program. But they've described scalability when talking about what's needed.
The verdict of history is unanimous: human beings can find trouble anywhere, and always do. We're geniuses when it comes to messing things up.
It's time for the compliance community to be hopeful. In the same month, the DOJ announced it was hiring a compliance expert to help make charging decisions, and an administrative law judge refused to allow the SEC to sanction a former Wells Fargo Advisors compliance officer because doing so would make her a scapegoat.
For us lawyers who practice in-house, we've witnessed through the years a huge change in the field of corporate governance -- the system by which a company is managed and controlled.
Is this one of the biggest scandals ever, not by money but by scope and the billions of ordinary folk affected all at once? From a quick search of the FCPA Blog archives (see the menu bar above), it looks like it.