In the 10th edition of the “OIG Shorts” series, Sheppard Mullin’s Organizational Integrity Group continues its exploration of a number of complex compliance matters with a discussion on Setting the Table for Good Decision-Making: And Making Sure the Chief Legal Officer Has a Seat at It. This post discusses why it’s important that Chief Legal Officers and Chief Ethics & Compliance Officers have meaningful, real-time involvement in the key legal, organizational, reputational, and business discussions/decisions of their companies, as well as direct access to the Chief Executive Officer and the Board.
Jonathan Aronie is the Leader of the firm's Governmental Practice Group and is a former Managing Partner of the Washington, D.C. office. Jonathan also is a founding member of the firm's Organizational Integrity Group, a cross-disciplinary team of litigators, regulatory specialists, federal monitors, and ex-prosecutors with extensive experience helping organizations prevent and defend against challenges to their organizational integrity.
This month, Sheppard Mullin’s Organizational Integrity Group continued its exploration of a number of complex compliance matters as part of their “OIG Shorts” series with a discussion on Understanding the Various Layers of a Targeted Compliance Program. This post discusses the importance of a targeted, multi-layered compliance program focused at individual deals, sales, contracts, etc. – as distinguished from the equally important company-wide E&C program previously discussed.…
Many business leaders still view Ethics & Compliance as a cost center rather than a cost reducer. This thinking can create quite the hurdle for CECOs looking to secure a…Continue Reading Organizational Integrity Shorts: Ethics & Compliance Program Funding
Previous installments of OIG Shorts addressed practical approaches to creating a more effective Ethics & Compliance program. The sixth installment of OIG Shorts focuses on the importance of measuring the…Continue Reading Organizational Integrity Shorts: Measuring The Efficacy Of Your Ethics & Compliance Program
Discipline is a complicated thing. Ask any parent. The fifth installment of OIG Shorts focuses on discipline as a core component of an effective Ethics & Compliance Program.
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In our decades working with complex organizations on their Ethics & Compliance (E&C) programs, my colleagues and I have seen a wide variety of structures. While we readily concede there…Continue Reading Organizational Integrity Shorts: Structure Matters
Welcome to our third installment of OIG Shorts. Ethics & Compliance programs that buck up against an employee’s reality—whether that reality is real or perceived—have less chance of succeeding. In…Continue Reading Organizational Integrity Shorts: Reality Based Ethics & Compliance Programs
Welcome back to our second installment of OIG Shorts. In this post, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity Group focuses on the difference between Checking Boxes and…Continue Reading Organizational Integrity Shorts: Everyone Benefits When An Ethics & Compliance Program Is Integrated Throughout An Organization
Over the course of the next few months, the Sheppard Mullin Organizational Integrity Group will be exploring a number of complex compliance matters in a series we call “OIG Shorts.”…
The inattention some companies pay to their ethics and compliance program never ceases to surprise us. You’d think the frequency of DOJ press releases and prosecutions holding companies accountable for employee wrongdoing would be enough to scare any business into directing more resources at prevention. But alas, many businesses, often over the protestations of their under-resourced Chief Ethics and Compliance Officers (CECOs), continue to think they can get by with a minimalist approach to ethics and compliance. Our experience suggests otherwise.
Continue Reading DOJ’s Renewed Focus On Corporate Ethics & Compliance Programs Highlights Importance Of Organizational Integrity
Government enforcement efforts are on the rise. In December 2021, the Secret Service announced an initiative to more aggressively counter pandemic-related fraud. Empowered by new personnel, new funding, and new legislation, the DOJ has bolstered its antitrust enforcement efforts. Gurbir Grewal, the SEC’s new director of enforcement, shared his aggressive SOX enforcement plans in a recent PLI speech. Speaking at the ABA 36th White Collar Crime Institute, Deputy AG Lisa Monaco announced the DOJ would be re-energizing its enforcement of “white collar” wrongdoing. “Although we understand the costs that enforcement actions can place on shareholders and others,” she told the audience, “our responsibility is to incentivize responsible corporate citizenship, a culture of compliance and a sense of accountability.”…
Continue Reading Driving Cultural Change To Reduce Corporate Risk: Lessons Learned From The Field