There are times when facts which arise out of
non-compliance matters can make excellent learning points for the compliance
practitioner. The Olympus matter has become such a staple of teaching
opportunities. It initially appeared that the primary lessons...
I often write about what I call the McNulty Maxims of
Compliance. I heard them in a presentation by Paul McNulty to the Houston
Chapter of the Texas General Counsel Association in my most recent corporate
position. They were (1) What did you do to...
In an article in the most recent issue of the Houston
Business Journal, entitled " Putting a partner through too many changes
increases risk ", columnist Connie Barnaba discusses one of the risks often
overlooked in a mergers and acquisitions...
The debate now ongoing in the UK about whether Deferred
Prosecution Agreements (DPA) should be a tool available to prosecutors in the
Serious Fraud Office (SFO) and Crown Prosecutors is an important issue that
should be well reasoned and thoroughly...
Two articles this week spoke about the continuing
struggle companies have with the issue of agents and other third party
representatives and the potential liability under the Foreign Corrupt Practices
Act (FCPA). In an article in the Wall Street Journal...
An article in the most recent issue of the ABA Business
Torts Litigation Section Newsletter, entitled " Use of the
FCPA in State-Law Unfair Competition Cases ", Edward Little, Jr.
explores the question of whether the Foreign Corrupt Practices...
One of the complaints made about the Department of
Justice (DOJ) is that companies are not made aware of the requirements of a best
practices compliance program. However, since the summer of 2010, the DOJ
has appended to each Deferred Prosecution Agreement...