Compliance Usa


    … 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…

    Wolf M. Nietzer/ USA Recht- 49 Leser -


    … including training, is the 2012 publication entitled “FCPA – A Resource Guide to the U.S. Foreign Corrupt Practices Act”, which was issued jointly by the Criminal Division of the Department of Justice (DOJ) and the Enforcement Division of the Securities and Exchange Commission (SEC). This FCPA Resource Guide provided the government’s views on what…

    Wolf M. Nietzer/ USA Recht- 66 Leser -
  • Compliance Training – Part II: Risk Ranking and Design

    …. Accordingly, Department of Justice (DOJ) and Securities and Exchange Commission (SEC) will evaluate whether a company has taken steps to ensure that relevant policies and procedures have been com­municated throughout the organization, including through periodic training and certification for all directors, officers, relevant employees, and, where…

    Wolf M. Nietzer/ USA Recht- 79 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

    … compliance program and your business model to see what are your highest risks. If you believe there are several, you can fprioritize them. This exercise will give you the basis to deliver your ever-scarcer compliance resources to your highest risk areas. While I do not believe the Department of Justice (DOJ) or Securities and Exchange Commission (SEC…

    USA Recht- 43 Leser -
  • Revisiting The Raven and Visiting Foreign Subsidiaries

    … On January 19 we celebrated the birth of one of America’s most iconic authors, Edgar Allen Poe, who was born on this day in Boston, Massachusetts. Anyone who reads or watches a mystery show on television owes a debt to Poe for inventing the genre. Poe flunked out of West Point but later became an editor at the Southern Literary Messenger…

    USA Recht- 36 Leser -
  • Does Your Company Still Allow Facilitation Payments?

    … conclusion date at this time. 3. Some Guidance So what does the Department of Justice (DOJ) look at when it reviews a company’s FCPA compliance program with regards to facilitation payments? Initially, if there is a pattern of such small payments, it would raise a Red Flag and cause additional investigations, but this would not be the end…

    USA Recht- 46 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- 46 Leser -
  • United States: Timing May Be Everything In Breach Of Warranty Claims

    … In the wake of the recent recalls and warranty campaigns, suppliers should bear in mind the threshold statute of limitations defense that they may have to any attempts by the OEMs to recover against them for costs for issues that the OEMs may have known about for years, but failed to act upon. An OEM seeking to recover against a supplier…

    USA Recht- 44 Leser -

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