Over the past few months, the OIG shorts series focused on structuring and implementing a comprehensive and effective ethics and compliance program. Many times, this requires a mindset shift from a checking-the-box mentality to a wholistic approach in which everyone feels they have an important role to play. Nowhere is this more apropos than in the area of cybersecurity including developing a data security strategy and maintaining an effective incident response plan.
There is a compliance obligation that is sometimes honored in the breach: regular compliance self‐assessments. In this edition of OIG Shorts, the Sheppard Mullin Richter & Hampton LLP Organizational Integrity…Continue Reading Organizational Integrity Shorts: Compliance Self-Assessments
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
This past month, the U.S. Senate debated a provision in the Innovation and Competition Act that would require the Committee on Foreign Investment in the United States (CFIUS) to review any proposed gifts and contracts of $1 million or more to U.S. research institutions from a foreign source. That would mean that the U.S. government would have a new level of oversight of such gifts, be required to investigate the ultimate source of the funds, and be able to impose mitigation measures on or prohibit such gifts.
Continue Reading Open Research, Foreign Finance, and a University’s Mission
Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA investigations were initiated. We expect the Biden Administration to continue the trend of increasing FCPA enforcement settlement values, while also increasing the pace of initiating new FCPA investigations. Anticorruption matters present some of the most severe threats to a company’s organizational integrity. Understanding the changing enforcement culture is an important component to addressing those threats.
Continue Reading The Next Four Years of FCPA Enforcement: What to Expect From the Biden Administration
This article was originally published on IP Watchdog.
An employee comes to you with a recipe for your competitor’s “secret sauce.” You know she worked for your competitor before coming to work for you. How do you respond? It’s an important question, because it may go to the core integrity of your organization and because exploring this trade secret conundrum may offer some decision-making principles that businesses can apply when addressing other difficult decisions that they are being called to make in these stressful COVID-19 times. …
Continue Reading To Disclose Or Not To Disclose: Responding to Trade Secrets Misappropriation by an Employee?