3 DOJ Questions:Do compliance personnel have the right expertise? What do low level employees know about compliance? What are management and the board doing in terms of compliance? These were some of the compliance questions announced by the DOJ on February 9, 2016.
68%Countries worldwide that have a serious corruption problem. Half of the G20 are among them. (Transparency International Corruption Perceptions Index 2015)
$37 millionTotal paid by the SEC in 2015 to whistleblowers for information leading to enforcement actions with monetary sanctions exceeding $1 million.
$650 millionWalmart’s legal fees and other costs associated with DOJ and SEC investigations of alleged FCPA violations, including revamping its global compliance program. (2012 to date)
1. Single Compliance Program: A “one size fits all” compliance program does not often work. Must take into account risk/cultural aspects of every country and have a proportionate global program. Must be able to demonstrate compliance program works effectively and has been tested: Prevent-Detect-Respond. Materiality does not matter, issue is whether your internal control system works effectively