Best Practices

    • Compliance Training – Part II: Risk Ranking and Design

      Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and assess an effective compliance and ethics training program. This series was inspired by an article in Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by L.V.

      Wolf M. Nietzer/ USA Recht- 31 Leser -
    • COMPLIANCE TRAINING, PART I

      In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees but simply to check the box that training has occurred. She also spoke against “dumbed-down nature of most compliance courses”.

      Wolf M. Nietzer/ USA Recht- 27 Leser -
  • Leifaden für IT-Sicherheit im Auto

    … „Auto Information Sharing and Analysis Center“, oder kurz Auto-ISAC, der US-Industrieverband für Sicherheit in der Automobiltechnik, hat einen Leitfaden für mehr IT-Sicherheitbei Automobilen sorgen soll. Er richtet sich vor allem an die Automobilhersteller und deren Zulieferer. ZWECK DES LEITFADENS Zweck des Leitfadens ist es dabei, dass die betroffenen Unternehmen anhand on „Best Practices“ einen Anhaltspunkt […]…

    Gerald Lill/ Datenschutzblog 29- 59 Leser -


  • Compliance Training – Part II: Risk Ranking and Design

    … Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and assess an effective compliance and ethics training program. This series was inspired by an article in Slate, entitled “Ethics…

    Wolf M. Nietzer/ USA Recht- 65 Leser -
  • Senn on 10 Best Practices in a Cross-Border Investigation – Part II

    … series on how to formulate an effective best practices cross-border investigation based upon an interview I did with Mara Senn, a partner at Arnold & Porter LLP, who specializes in white collar defense and cases brought under the Foreign Corrupt Practices Act (FCPA). The interview was based on an article that Senn and a colleague, Michelle Albert…

    USA Recht- 46 Leser -
  • Senn on 10 Best Practices in a Cross-Border Investigation – Part I

    … this best practice is that your analysis and response must go much further to satisfy the US Department of Justice (DOJ) if you want to claim that you cannot get certain information out of a country because of data privacy restrictions. For instance if you have personal data that you are routinely sending cross-border yet when an investigation begins…

    USA Recht- 56 Leser -
  • Managing Your Third Parties in a FCPA Compliance Program

    … The building blocks of any Foreign Corrupt Practices Act (FCPA) anti-corruption compliance program lay the foundations for a best practices compliance program.For instance in the lifecycle management of third parties, most compliance practitioners understand the need for a business justification, questionnaire, due diligence, evaluation…

    USA Recht- 34 Leser -
  • Doing Less with Less and the Unification of Germany

    … I am attending the SCCE Utilities and Energy Conference in Houston this week. As usual, the SCCE has put on a great event for the compliance practitioner. This year there is live blogging by Kortney Nordum so there should be much about the conference up on the SCCE blogsite, this week and into the future. Lizza Catalano has put together a first…

    USA Recht- 34 Leser -
  • Revisiting The Raven and Visiting Foreign Subsidiaries

    … of foreign subsidiaries on how to manage the attention of headquarters staff.” Given the current attention that Chief Compliance Officers (CCOs) and compliance practitioners need to spend on China specifically, and international operations more generally, I thought the article had some excellent insights for the compliance function going forward…

    USA Recht- 29 Leser -
  • Doing Business in India – Corruption Risks and Responses

    …, the Department of Justice (DOJ) would say the risk is high because of the number of licenses and permits required. More pruriently, I would say this leads to more folks having their collective hand out looking to speed things up. Indeed, in the recently released TRACE Matrix India comes in at 185th out of 197 countries listed, with a corruption score…

    USA Recht- 37 Leser -
  • Due Diligence Going Forward in China

    … is a “chilling effect on companies that engage in due diligence work for global companies, many of whom believe the couple may have been unfairly targeted.” The WSJ article went further quoting Geoffrey Sant for the following, “It impacts all attempts to do business between the U.S. and China because it will be very challenging to verify the accuracy…

    USA Recht- 59 Leser -
  • Termination of a Third Party or Breaking Up Should Not Be Hard To Do

    … One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does Switzer write a highly informative and useful column but she also includes two standard features. The first is an illustrated…

    USA Recht- 39 Leser -


  • Code of Conduct, Compliance Policies and Procedures-Part I

    … drafting your Code of Conduct and anti-corruption compliance policies and procedures and how to assess, review and revise them on a timely basis. The cornerstone of a US Foreign Corrupt Practice Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. These requirements have long been memorialized…

    USA Recht- 66 Leser -
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