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.
75%Transparency International’s 2017 Corruption Perceptions Index highlights that the majority of countries are making little or no progress in ending corruption. For 2017, the index found that more than two-thirds of countries score below 50, using a scale of 0 to 100, where 0 is highly corrupt and 100 is very clean.
$250 millionAmount awarded by the SEC to whistleblowers since the inception of the agency’s whistleblower program in 2011. Enforcement actions from whistleblower tips have resulted in more than $1 billion in financial remedies.
$820 million and risingWalmart’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