Sam E. Antar, the convicted felon and former CEO of Crazy Eddie, puts forth the theory that the bad economy is accusing white collar crimes to float to the surface: Is there really more white collar crime today? No. The Madoff scheme is an example of a scheme that fell apart whent he markets went … Read more »
Siemens to Pay Huge Fine in Bribery Inquiry
The DOJ’s Information charging Siemens in the biggest FCPA enforcement action ever tells of more than 4,000 payments worth at least $1.4 billion to foreign officials to obtain or retain business. Siemens also had systematic and intentional violations of the internal controls and books and records provisions that might have prevented or detected the corrupt … Read more »
Red Flags in the Madoff Case
Gregory Zuckerman of the Wall Street Journal put together a story on the Multiple Red Flags in Madoff Case. Steady returns in every kind of market Operated as a broker dealer with an asset management division. Why not simply act as a hedge fund and pocket big gains, rather than profit from trading commissions. “Why … Read more »
The Contribution Revolution
The October issue of the Harvard Business Review has an article by Scott Clark: The Contribution Revolution – Letting Volunteers Build Your Business. Mr. Clark challenges companies to tap into the contributions of people beyond their organizations. (He has clearly driven the Kool-Aid offered by Don Tapscott in Wikinomics.) One section caught my attention: I … Read more »
Legal Insider Trading
Bruce Carton of Compliance Week and Securities Docket put together examples of “Legal Insider Trading” on his Enforcement Action blog. Read more »
What Is Your Scope of Compliance?
Unified Compliance Framework put together this list of compliance requirement and regulatory schemes that may need to be part of your compliance program. Below is a long list of regulatory schemes that may need to be part of your compliance framework: Sarbanes Oxley Guidance Sarbanes-Oxley Act (SOX) PCAOB Auditing Standard No. 2 AICPA SAS 94 … Read more »
Guidance Concerning the National Security Review Conducted by the Committee on Foreign Investment in the United States
On December 8, the Committee on Committee on Foreign Investment in the United States published a notice in the Federal Register of that provides guidance to U.S. businesses and foreign persons that are parties to transactions that are covered by section 721 of the Defense Production Act of 1950, as amended by the Foreign Investment … Read more »
Intel’s Social Media Guidelines
Intel has published their Social Media Guidelines. I like their approach of giving users guidelines for they should and should not do. The context is to place the responsibility on the individual. It is that person who is creating the content. They are responsible for the content and the consequences. I think it is a … Read more »
Building an Ethical Framework
Thomas R. Krause and Paul J. Voss put forth 10 questions to consider in encouraging an ethical corporate culture. What is the relationship between ethics and other performance metrics in the company? Have we, as required by the 2004 federal sentencing guidelines, offered ethics training for all of our employees? Does the training provide more … Read more »
Compliance Boundaries
One way to view compliance policies is grouping them into mandatory and voluntary policies. Mandatory are those dictated by law. Voluntary are those the organization has imposed to futher business objectives and manage risk. Thanks to Carole Switzer, President of OCEG for this perspective. Read more »