MyComplianceOffice Blog

Approximately 90 percent of  Foreign Corrupt Practices Act (FCPA) enforcement actions involve a third party. That’s according to a recent article in the FCPA blog. The U.S. Department of Justice (DOJ) has taken notice, including an entire section on third-party risk management as part of its updated guidance for evaluating corporate compliance programs. 

Integrating the compliance function into an organization’s C-Suite not only improves crisis preparedness but also helps protect the bottom line. Performing that integration is not always so easy, however. The first roadblock is the C-level structure itself. 

The U.S. Securities and Exchange Commission (SEC) approved new conflict of interest rules for brokers this past week. The regulations mandate brokers act in the “best interest” of clients. They require the financial services industry to clamp down on potential conflicts such as contests rewarding brokers for selling more securities than peers and exclusively selling their employers’ products.  

The U.S. Supreme Court recently held protections in the International Organizations Immunities Act of 1945 against civil lawsuits in U.S. courts were not absolute. Instead, immunity granted to international organizations, including Multilateral Development Banks (MDBs), is no greater than that enjoyed by foreign governments under the Foreign Sovereign Immunities Act (FSIA).  

A 2019 study by Strategy&, the strategy consulting arm of PwC, found for the first time ever, more CEOs were forced out of their organizations for ethical lapses than for poor financial performance or conflicts with their Board.