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Economic Downturn Week, Part I – Mapping of Your Internal Compliance Controls
This week I will present a series on steps that you can take in your compliance program if you find yourself, your company or your industry in an economic downturn. All of the recommendations I will...
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Economic Downturn Week, Part II – The Golden Gate Bridge and Employment...
Today, we celebrate one of the greatest engineering achievements of the century. On this date in 1937, the Golden Gate Bridge opened. At 4200 feet long, it was at the time the world’s longest...
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Economic Downturn Week, Part III – The Desktop Risk Assessment
I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at...
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Like a Rolling Stone and Charitable Donations Under the FCPA
Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives...
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Mifune Gets a Star on the Walk of Fame-the Petrobras Scandal Only Gets Worse
It was announced last week that actor Toshirō Mifune (1920-1997) will be honored with a star bearing his name on the Hollywood Walk of Fame. The Hollywood Chamber of Commerce will add the star in 2016,...
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What Would Dr. Seuss Say about an Allowance?
Earlier this month we had the release of a second book by Harper Lee, “Go Set a Watchman”, which was miraculously discovered having been written some 50+ years ago. This week, there was another release...
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Cymbeline – Doing Virtue and FCPA Compliance
Commentators still level the hue and cry that it is somehow the fault of the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) that companies continue to violate the Foreign...
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The BHP Case and Enforcement of The FCPA’s Internal Controls Provision
Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action....
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BNY Mellon Settles First Sons and Daughters (and Nephews) FCPA Hiring Matter...
Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was...
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BNY Mellon and Lessons Learned In Hiring Family Members – Part II
In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around...
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