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…

    Wolf M. Nietzer/ USA Recht- 39 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- 38 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- 72 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

    … downturn is on everyone’s mind and a subject of much conversation. Last week I wrote a post about the depression of oil and gas prices in the energy space and some of the increased Foreign Corrupt Practices Act (FCPA) or other anti-corruption risks that might well arise from this economic downturn. Over the next couple of days, I want to explore how…

    USA Recht- 40 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- 35 Leser -
  • Does Your Company Still Allow Facilitation Payments?

    … prohibiting corruption and bribery. Further, the FCPA Guidance specifies, “while the payment may qualify as an exception to the FCPA’s anti-bribery provisions, it may violate other laws, both in Foreign Country and elsewhere. In addition, if the payment is not accurately recorded, it could violate the FCPA’s books and records provision.” Finally, further…

    USA Recht- 45 Leser -
  • Termination of a Third Party or Breaking Up Should Not Be Hard To Do

    …” with participants Walter Hoogmoed, Jr., a Principal at Deloitte, Marie Patterson, VP-Marketing at Hiperos, and Billy Spears, Chief Ethics, Privacy and Compliance Officer at Hyundai Capital America. Switzer begins by noting that it all should begin with “an exit strategy, a transition plan or a pre-nup—whatever the title, it’s best to begin…

    USA Recht- 43 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- 43 Leser -


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