Compliance Usa

    • 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- 32 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- 29 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…

    Wolf M. Nietzer/ USA Recht- 49 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- 66 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- 35 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- 30 Leser -
  • Does Your Company Still Allow Facilitation Payments?

    … One of the more confusing areas of the US Foreign Corrupt Practices Act (FCPA) is in that of facilitation payments. Facilitation payments are small bribes but make no mistake about it, they are bribes. For that reason many companies feel they are inconsistent with a company culture of doing business ethically and in compliance with laws…

    USA Recht- 44 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 -
  • 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- 42 Leser -


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

    … in the US Federal Sentencing Guidelines (FSG), which contain seven basic compliance elements that can be tailored to fit the needs and financial realities of any given organization. From these seven compliance elements the Department of Justice (DOJ) has crafted its minimum best practices compliance program, which is now attached to every Deferred…

    USA Recht- 67 Leser -
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