There was Congressional testimony last fall to consider
possible modifications to the Foreign Corrupt Practices Act. In part the
testimony focused on the issue of FCPA compliance procedures as a defense for a
business organization. Under current practice...
In an article in the July/August edition of the ACC Docket entitled " Rethinking the Annual Compliance and Ethics Flea Dip ", author James Nortz discusses the annual compliance and ethics training program that most US company's employees...
Current trends in FCPA enforcement are evident in the
latest settlement with Johnson & Johnson. U.S. v. Depuy, Inc. ,
(D.D.C. Filed April 8, 2011); SEC v. Johnson & Johnson , Civil Action
No. 1:11-cv-00686 (D.D.C. Filed April 8, 2011). To resolve...
Who was Jeannette Rankin and why do we celebrate her
today in the context of ethics and compliance? She was the first female to be
elected to Congress, as a Representative from Montana in the 1916 elections. In
1917 she was one of 50 votes opposing...
Sedona Arizona is known for its four vortexes, some of those alleged places where the universe has holes in it or overlaps (I can’t remember which). I have been to Sedona but I have never experienced such convergence (or the voids for that matter...
In the June issue of the Harvard Business Review is
an article by Alan Grant entitled, " How
Customers Can Rally Your Troops ". In this article Grant argues that
"End users can energize your workforce better than your managers can."...
In the winter 2013 issue of the Colonial Williamsburg
magazine is an article by Michael Lombardi, entitled " Lighthouses Marked the
Shoals of the Commerce Clause ". In this article, Lombardi wrote about four
lighthouses authorized by Congress...
In an article published in the June issue of ACC Docket,
entitled " Playing the Cards You're Dealt ", James Nortz raised the
interesting issue of the lack of company leadership to "create an ethical
vision, the moral courage to pursue...
If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great battle concept. If you are Corbettian...
Yesterday we reviewed the background facts of the Johnson
& Johnson (J&J) Deferred Prosecution Agreement (DPA) and the issue of
self-reporting. In this posting we will review some of specific compliance
program best practices which Johnson...
In honor of the return of Sherlock Holmes to PBS with Season 3, I begin a week of Sherlockian themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange , he allowed a man who murdered a wife-abusing husband to go...
(Mealey's) - Johnson & Johnson (J&J) and
subsidiary DePuy International Ltd. will pay $76.9 million to resolve criminal
and civil allegations in the United States and in the United Kingdom that they
paid kickbacks to doctors in Greece,...
We have previously
written about the importance of getting your investigation right before
publicly announcing the results. In other words, do not allow your CEO,
as Renault did, to go on national television and decree that three (former)
Yesterday, I used some of the wisdom from current CIA
Director General David Petraeus to suggest how senior management might move
forward with a compliance program. Today I will use a very different individual
to help inform your third party due diligence...
In the September 2011 issue of the Harvard Business Review , in an article
entitled " How to
Cultivate Engaged Employees " , author Charalambos A.
Vlachoutsicos wrote about his experiences in working for a family-owned