Entries in Federal Sentencing Guidelines (81)
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.
I've been attending the HCCA's 19th Annual Compliance Institute this week in Lake Buena Vista, Florida.
Official expectations that companies will check to make sure that their compliance and ethics (“C&E”) standards are being followed have existed since the advent of the Federal Sentencing Guidelines for Organizations in 1991. Additionally, only a year later, a U.S. Department of Justice official emphasized the importance of auditing to antitrust compliance, which underscored that checking was expected not only regarding the overall compliance program (e.g., training, the hotline) but also substantive areas of risk. However, while checking expectations have been present from the beginning of the “Age of Compliance,” for many reasons they are more significant now than ever before.
The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda:
We provided a number of examples in the prior post when the DOJ funded community service projects with settlement money while fully complying with the MRA. Indeed, these projects have become more common, not less, in recent years.
Achieving consistent legal compliance in today’s regulatory environment is a challenge severe enough to keep compliance officers awake at night and one at which even well-managed companies regularly fail.
The FCPA Blog wanted to explore the idea of the dual-hatted compliance officer -- the one who occupies both the general counsel and chief compliance officer roles in a company. We talked with the former SEC Chairman and now Kalorama Partners CEO, Harvey Pitt. The conversation turned into a thoughtful exchange about what it means to be an independent and effective CCO in any industry today. Executive editor Julie DiMauro asked the questions for the FCPA Blog.
Before the Siemens case and the birth of the modern era of FCPA enforcement, there were the ten elements of an effective compliance program. They came from the U.S. federal sentencing guidelines applicable to corporate defendants.
A status conference in U.S. v. Weissman before Judge Barbara S. Jones in New York City has been scheduled for January 3.
The former director of worldwide sales for Control Components Inc. was sentenced Thursday to 13 months home confinement and fined $20,000 for bribing Chinese officials.