Organizational integrity

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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.…

Continue Reading Organizational Integrity Shorts: A Seat at the Table

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.…

Continue Reading Organizational Integrity Shorts: Understanding the Various Layers of a Targeted Compliance Program

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.…

Continue Reading Ethics & Compliance: Let’s Talk About Cybersecurity

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