It is difficult to keep a company on the path of legal compliance and to maintain its reputation especially since following the law does not necessarily protect an organization’s reputation. Recently, AT&T and Novartis experienced the pain a bad decision can have on reputation and financial value. The CEO’s for both Novartis and AT&T gave…
Managing investigations or investigators is never easy. Litigating is never easy either. But, it does not have to be as hard as Uber made it, which included inflaming a judge as well as garnering it bad press. In 2015, when Uber got smacked with an anti-trust lawsuit, Uber retained an investigative firm to look into…
Walking my dog the other day, I passed a “drug-free zone” sign and, smelling marijuana, smiled at the three guys standing there passing a joint. (Even with the new DC marijuana laws you still can’t light up on the streets, especially in front of the drug-free school zone.) The three guys were not just standing…
Entering a relationship with a new client, sales consultant, joint venture partner, or any other entity merits thoughtful consideration to protect your business’ value. Likewise, once you enter a relationship, you need to make sure the relationship stays healthy and productive over time. This is especially true when working with governments or doing business internationally…
Former Defense Secretary Donald Rumsfeld, when speaking about the Iraq War, took a lot of “writ” for saying there are unknown unknowns and that the unknown unknowns are difficult to manage. No doubt it is a weird statement on its face. But, most folks who manage risk for a living understand that the unknown unknowns…
FOCI – Foreign Ownership, Control and Interest Given the information and technology that U.S. defense contractors have and the role they play in U.S national security, U.S. defense contractors need to be particularly concerned about the dangers of the world. To manage the wild and dangerous world, regulations, particularly those detailed in the National Industrial…
“Oh baby, baby, it’s a wild world.” -Yusuf Islam, formerly known as Cat Stevens To assist businesses in operating in this wild world, the U.S. government tries to pass laws that it thinks will protect businesses and U.S. national security. The Foreign Agent Registration Act (22 U.S.C. 611 et seq.; 28 CFR Part 5) (FARA)…
At times, corporations and their leaders fumble when assessing legal risks. The result is trouble – corruption, procurement fraud, securities violations, inflated earnings, and trade violations. When it happens, it often results in criminal prosecutions, shareholder lawsuits, and negative media creating a perception that companies are filled with scoundrels. Often the prosecutions, the lawsuits and…
Do ethics and compliance have a price? Yep, and it varies depending on the scenario. But for this post, I am going to start my calculation at about $4.5 billion dollars. In 2015, Forbes Magazine put Ms. Elizabeth Holmes, founder and CEO of Theranos, on its list of the world’s richest self-made women with a…
Those in the ethics and compliance community and at the Department of Justice (DOJ) constantly chirp about the need for entities to have an ethics and compliance program which encourages not only compliance with laws, but ethical decision making. In fact, the Federal Sentencing Guidelines, the Federal Acquisition Regulations and other laws and regulations require…