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Friday Roundup

Roundup

Listening in, guilty plea, marketing the opaque, and machine learning. It’s all here in the Friday roundup.

Listening In

During a recent investor conference call, Cardinal Health executives were discussing how the company continues to evaluate which countries they should be in because “there’s a lot of hidden cost when you’re in a country.”

Company CEO Michael Kaufmann stated:

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Friday Roundup

Roundup

Head scratcher, expense reports, and third-party compliance. It’s all here in the Friday roundup.

Head Scratcher

In the bribery and corruption space, the DOJ and SEC frequently talk about their relationships with foreign law enforcement agencies including information sharing. For instance, FCPA enforcement agencies have stated:

“It is safe to say that we are cooperating with foreign enforcement on foreign bribery cases more closely today that at any time in history.”

“An international approach is being taken to combat an international criminal problem. We are sharing leads with our international law enforcement counterparts, and they are sharing them with us.”

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Issues To Consider From The Ericsson Enforcement Action

Issues

This previous post went in-depth into the Ericsson enforcement action and this post continues the analysis by highlighting additional issues to consider.

Record-Setting

Although there are certain haphazard FCPA top ten lists out there, the Ericsson enforcement action is the largest in FCPA history in terms of actual FCPA settlement amount. (See here for the current top ten list).

Record-Setting?

Even though the Ericsson enforcement action was record-setting, the question arises should it have been record-setting or was it an example of FCPA settlements increasing just because (see here for the prior post)?

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Assistant Attorney General Benczkowski On Corporate Compliance And His Odd Use Of The Term “Deterrence”

benczkowski

Last week Assistant Attorney General Brian Benczkowski gave this speech at the 20th Annual Pharmaceutical and Medical Device Compliance Congress – an event frequently on the DOJ’s speech calendar.

As highlighted below, Benczkowski delivered typical Department of Justice corporate compliance talking points.

However, what stood out in his speech was his repeated odd use of the word “deterrence.”

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