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.
Click here
Continue Reading Organizational Integrity Shorts: Let’s Be Disciplined About Discipline
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 U.S. Governmental Accountability Office (GAO) thinks the FBI and other agencies are not doing enough to address the espionage threat on U.S. university campuses. It issued a report, “Enforcement Agencies Should Better Leverage Information to Target Efforts Involving U.S. Universities” on June 14, 2022, urging the FBI, the Department of Homeland Security, and the Department of Commerce to step up their outreach efforts to address the threat. Commerce, DHS, and FBI have all concurred with GAO’s recommendations. As a result, U.S. colleges and universities to face yet another organizational risk: an increase in campuses visits by export control and law enforcement agents.
Continue Reading U.S. Government Pursues More Aggressive Action to Curb Espionage at Universities
So, nearly 2 years ago your organization applied for and received COVID-relief funds. The decision was not an easy one. On the one hand, government largesse invariably comes with strings and uncertainties, i.e., risk. On the other hand, your organization faced an unprecedented triple threat crisis: financial, operational, and health. Consumer spending plummeted and its consequences rippled through the economy threatening to trigger a global financial meltdown. You could not possibly have forecast how the global pandemic would affect your organization.
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
If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands don’t come from nowhere: consumers are demanding transparency and social responsibility. In addition, if your company does business internationally, regulators are now focused on international social justice issues (such as the use of forced labor) more than ever.
Continue Reading Does Your Trade Policy Support Your Company’s Values?