Earlier this week Richard Bistrong and Marc Hodak, writing for the FCPA Blog, considered how the Wells Fargo incentive system got so out of whack, and how this out-of-whackness contributed to the scandal around fraudulent account openings that has engulfed the bank since last August.
Entries in Hallmarks (7)
Leslie Caldwell, chief of the DOJ's criminal division, spoke at the Compliance Week Conference in Washington, D.C. Tuesday. After talking about some defenses that don't work, she described the ten hallmarks of an effective compliance program, and she warned companies to obey all the laws they're subject to.
Law-related employment for grads from American law schools isn't exactly robust. In 2013, the ABA Journal said, only 57 percent of the that year's JDs had full-time bar-passage-required jobs. At the same time, the world seems to have an insatiable appetite for compliance officers. That sounds like an opportunity.
Leslie Caldwell, chief of the DOJ's criminal division, talked at last week's Annual Ethics and Compliance Conference in Atlanta. She covered the ten hallmarks of an effective compliance program and cooperation with the DOJ in FCPA and other white-collar investigations. Her examples of good and bad corporate behavior came from real life.
As companies struggle to deal with compliance issues in the expanding global markets, they can no longer rely solely on automated compliance. Today compliance should also be intelligent.
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.