Cases that make one wonder about the intent of enforcement
By 
Tom Fox2018-11-28T15:30:00
A close look at FCPA investigations into Danske Bank, Goldman Sachs, and Walmart prompt more questions than answers.
THIS IS MEMBERS-ONLY CONTENT
You are not logged in and do not have access to members-only content.
If you are already a registered user or a member, SIGN IN now.
Related articles
-
OpinionCreating effective compliance messages for specific employee groups
As 2026 arrives, have you considered the efficacy of your compliance messaging efforts? We have all seen these compliance taglines “Speak Up!,” “See Something, Say Something,” “Ethics Matter!”
-
ArticleKaiser plans pay $556M to settle Medicare upcoding allegations
Kaiser Health affiliates have agreed to pay more than $556 million to settle allegations originally made by whistleblowers that they ignored compliance department warnings and unlawfully reworked diagnoses for Medicare patients in order to receive higher payments from the federal government.
-
ArticleFTC files contempt against credit card processor Cliq for alleged ongoing compliance failures
The Federal Trade Commission asked a court to hold the payment processor Cliq in contempt for allegedly “flagrantly” violating a 2015 order that the company monitor transactions for illegal charges and activity.
More from Opinion
-
OpinionTeaching the business to speak risk
Compliance professionals understand the value of risk assessments. We conduct them annually, map risks to controls, and present heat maps to the board. But there is a strategic opportunity that many compliance programs overlook: Teaching the business itself to think in the language of risk.
-
OpinionSOX was built for humans. AI doesn’t fit that model.
For more than two decades, assurance and compliance frameworks have rested on a simple assumption: Material decisions are made by people. Post‑Sarbanes-Oxley Act (SOX) assurance reset worked because it aligned accountability with human behavior. That assumption shapes how internal controls are designed, how accountability is assigned, and how assurance is ...
-
OpinionManaging the permanent tension between compliance and business delivery
Business delivery runs on market deadlines. Compliance runs on regulatory mandates.