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The role of ethics in a deregulated 21st century
Normative ethics seeks to set norms or standards for conduct. The term is commonly used in reference to the discussion of general theories about what one ought to do, a central part of ethics
Read More »The Role of a Board in Compliance and Ethics: How We Arrived and Where We Are Going
Yesterday, the Houston Astros traded Wandy Rodriguez, the last remaining member of the 2005 National League (NL) champs. The Astros have traded away their five ‘top’ players over the past three weeks, coincidently turning
Read More »Five Basic Pillars of an Effective Compliance Program
Everyone in the compliance community likes to cite the required elements of an anti-corruption compliance program. The Justice Department and the SEC have described the required elements over and over again in Schedule
Read More »The “Greatest” Risk of All – The False Claims Act
Companies complain about the burdens of anti-corruption compliance. They need to put things in perspective. The “greatest” risk of them all may be the False Claims Act (FCA). FCA violations can lead to severe consequences,
Read More »Ethical Leadership: Leading a Company Conversation on Compliance
Ethical leadership is absolutely mandatory to have a successful compliance program, whether it is based upon the US Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act. Senior management must not only be
Read More »Ethical Leadership: Leading a Company Conversation on Compliance
Ethical leadership is absolutely mandatory to have a successful compliance program, whether it is based upon the US Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act. Senior management must not only be
Read More »The Lifeblood of Every AML Compliance Program: Suspicious Activity Reports
As anti-money laundering laws and regulations expand to new entities, compliance officers need to focus on the design and implementation of suspicious activity reporting systems. SARs are at the center of every AML compliance program,
Read More »Antitrust Enforcement and Compliance Keeps Chugging Along
The Justice Department’s criminal enforcement of antitrust laws is a model of success. DOJ’s criminal program took off in the 1990s with two major developments: (1) adoption of a corporate leniency program which
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