Public companies aren’t the only ones struggling to get governance right. Would-be public companies appear to share their pain, according to surveys conducted by KPMG LLP. In a series of polls conducted by the Big 4 firm, companies preparing for an initial public offering cited improving corporate governance as their top challenge. Asked to name […]
Melissa Klein Aguilar
Managing, Mitigating Third-Party Risks
For most companies these days, working with third parties is critical to doing business. But at a time when anti-corruption enforcement has never been more stringent, those third parties can also pose huge risks. The biggest third-party risk of all is violation of the Foreign Corrupt Practices Act—and for U.S. companies working with hundreds or […]
Tips for Structuring the Compliance Department
The structure of corporate compliance departments has become a hot topic lately, thanks in particular to amendments to the U.S. Sentencing Guidelines that put a spotlight on compliance officer’s reporting authority and independence. No single “right way” exists to structure a compliance department, but at Compliance Week 2010, compliance leaders from large and small companies […]
SEC Settlements Up in First Half, Driven by Individuals
The uptick in Securities and Exchange Commission settlements continued during the first half of the year-much of it due to settlements with individuals. According to data tracked by NERA Economic Consulting, the SEC settled with 354 defendants in the first half of 2010, compared with 328 in the second half of 2009 and 290 in […]
Grindler Memo Adds 10th Principle on Monitors
Federal prosecutors ought to be clearer about what help they can provide to companies having issues with corporate monitors assigned to them as part of settlements with the Department of Justice. That’s the gist of new internal DoJ guidance, detailed in a May 25 Memo written by Acting Deputy Attorney General Gary Grindler, which says […]
Chipping Away at Effective Anti-Corruption Programs
Attendees at the Compliance Week 2010 conference last week got a refresher course in the compliance challenges and litigation risks stemming from bribery and corruption—and given the fast-changing regulatory landscape around corruption, Corporate America needs the extra help. “We’re in a world where you’re not just dealing with the Securities and Exchange Commission and the […]
Experts Speak on Using Social Media for Good
Amid headlines trumpeting privacy failures and PR nightmares stemming from employee use of popular social media tools such as Facebook and YouTube, it’s no surprise that many companies still struggle with whether and how to dip their toes in the social media pool. Done right, online social media can help a company build its brand. […]
DoJ Warns on Heightened Fraud Enforcement
As the Justice Department ramps up its efforts to combat all forms of fraud, two of its top officials gave corporate compliance, legal, and risk professionals the straight dope on what they must do to keep their companies out of trouble. In separate remarks at the Compliance Week 2010 conference last week, Acting Deputy Attorney […]
Another Delay for FTC Red Flags Enforcement
The Federal Trade Commission has again delayed its enforcement of the “Red Flags” Rule until year-end at Congress’ request, as lawmakers work on legislation to limit the scope of entities covered by the rule amid legal battles over its application. The Red Flags rule, which requires certain businesses to develop and implement written identity theft […]
Warning, Tips From Justice Department’s Grindler
Corporate compliance, legal and risk professionals got a warning from a top Justice Department official, along with some advice on how to keep the companies they work for out of trouble. Acting deputy attorney general Gary Grindler made it clear that the agency is taking a no holds barred approach to cracking down on corporate […]


