Donna Boehme – The FCPA Blog – March 9, 2017 This article first appeared on the FCPA Blog. In the Justice Department’s new guidance for compliance programs, which appeared online unannounced, undated and unsigned, one detects…
Joe Murphy – Compliance & Ethics Professional – March 2017 In a previous column, I discussed the range of options for discipline. In this column, I address factors to consider in imposing discipline. The prior…
Donna Boehme – The Compliance & Ethics Blog – February 28, 2017 Ever since the news broke of various VW execs being arrested, including the US-based compliance “environment and emissions manager,” I’ve seen some mild hysteria…
Donna Boehme – Corporate Compliance Insights – February 2017 I recently read a great blog post by Tom Fox on why compliance officers need independence. And former federal prosecutor Michael Volkov, who completely understands the…
Joe Murphy – Compliance & Ethics Professional – February 2017 I recently gave a talk to a Fordham Law School class on discipline in compliance programs. On this subject, I find people understand the need…
Donna Boehme – The FCPA Blog – January 13, 2017 This article first appeared on The FCPA Blog. Read the full story here. While still within shouting distance of January 1, I’d like to set…
Joe Murphy – Compliance & Ethics Professional – January 2017 Compliance and ethics professionals have enough lists of things to do. There is the Sentencing Guidelines list of seven steps. The OECD Good Practice Guidance contains a…
Donna Boehme – Corporate Counsel – December 1, 2016 This article first appeared here on Corporate Counsel. Roy Snell, executive director of the Society for Corporate Compliance and Ethics, is a great thought leader for…
Donna Boehme – The FCPA Blog – December 6, 2016 This article first appeared here on the FCPA Blog. I know that the compliance professionals in my networks understand, now more than ever, that choices…
Joe Murphy – Compliance & Ethics Professional – December 2016 When the Sentencing Guidelines were adopted in 1991, it was recognized that this was an experiment. It is still an ongoing experiment, and like any…
