2018 - 2017

November 18 - ISO 37001 on anti-corruption compliance management systems has been unusually controversial. Joe proposes starting a discussion on the FCPA blog on how to fix ISO 37001 and the certification process.

August 7 - Professor Paul McGreal and Joe Murphy have pointed out that even though New York City has enacted what has been described as “the nation’s furthest-reaching anti-sexual harassment laws,” it is questionable how serious an effort this really is. In other compliance areas, where companies want to prevent misconduct, there is much more that is expected of them. Only in the area of harassment are they simply asked to do paper and preaching, tell people to call HR, investigate if anyone does call, and not much more.

We may be saying “me too,” but if we were serious about it we would be doing much more.

December 8 - On behalf of SCCE, Joe Murphy has filed comments with the Department of Justice’s Deputy Assistant Attorney General Rod J. Rosenstein.  In his speech of October 6, 2017 DAG Rosenstein invited comments on the Department of Justice’s enforcement policies. Among other points,  the filing challenges the inconsistent approaches taken to compliance programs, and particularly the Antitrust Division’s odd policy of only rewarding companies that refrain from implementing compliance programs until they are caught after a violation. This one unit refuses to consider preventive compliance programs, in conflict with the rest of the Department of Justice.  This creates an unfair environment where those outside the Department do not know whether or not compliance programs actually count in dealing with the Department.

Read the letter below.