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Why Client-Attorney Privilege Matters for Compliance Officers

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From China to Brazil, Morocco to Russia, emerging markets are extremely important to established companies, because of their potential for growth and the many new business opportunities they represent. While tapping into these markets promises big benefits to global organizations, those benefits come with additional challenges and risks, particularly in terms of corruption and bribery. In this ...
“Client-attorney privilege” is one of those terms that pops up with some regularity on police procedural TV shows like the “Law & Order” series. The basic goal of this privilege is to encourage full and frank communication between attorneys and their clients by protecting those communications. But did you know that this privilege can also apply to internal compliance investigations and the work ...
A compliance problem can become a crisis when internal investigations and communications are mishandled. While people typically associate crisis leadership with an organization’s CEO or board, the role of the Chief Compliance Officer (CCO) has become more visible as internal corruption investigations have become more widely reported by the media. The CCO must be ready to step into a leadership ...
We’ve all heard the cliche that “The only constant is change.” Well, those words are not true—because for 15 years, compliance officers have asked me the same question over and over. 
Training programs are the lifeblood of an effective corporate compliance program, and the same logic that lies behind the success of a compliance program applies for training: Successful training must match the risk a company has to employees and third parties. It should clearly communicate the policies governing that risk and provide employees with the appropriate tools to avoid it. Seems ...
When it comes to compliance issues or bribery concerns, every situation is different, and your organization’s response should be reasonable and proportional to those circumstances. Let’s say that someone has claimed that an employee is taking friends to dinners and being reimbursed as if these friends were potential customers. In this case, it would probably be overkill to bring in outside ...
When a compliance issue is raised, the organization’s response should be reasonable and proportionate to the circumstances. For compliance professionals, the witness interview plays a critical role in determining the scope of an internal investigation.
Let’s say you’ve put together a great compliance program, with policies in place to reduce business risk and curb corruption. But how do you know your program is actually working? If you know your program still needs to address a specific risk, how do you make your case for additional resources?
The Justice Department’s FCPA Pilot Program turns one year old this month. Celebrate if you feel the urge, but news of its extended lease on life—which a Justice Department official announced in March—should surprise nobody. The Pilot Program fits exactly with the Trump Administration’s emerging message on policing against corporate misconduct. Yes, technically the Justice Department is extending ...
Some companies question whether or not they should invest in a full-fledged compliance program. While the return on investment isn’t always obvious, a strong program can help your company avoid fines and legal expenses. In the United States, the Department of Justice (DOJ) and the Securities Exchange Commission (SEC) sometimes decline to pursue charges due to a company having an effective ...