Enforcement Issues and Trends Affecting the US Automotive and Mobility Industry | Morgan Lewis jdsupra.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from jdsupra.com Daily Mail and Mail on Sunday newspapers.
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When will the next compliance crisis occur? As we learned from the recent SAP trade sanction enforcement action, it can be quite some time from a change which leads to a violation that leads to an enforcement action. In this case for SAP, it was acquisitions in the early 2010s, who had violations from 2010 to 2017, that led to the 2021 enforcement action. Foreign Corrupt Practices Act (FCPA) enforcement actions can have an equally long, if not longer, number of years where a series of unfortunate events can lead to costly investigations and enforcement actions.
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While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns.
We have to recognize that 2020 was a difficult and unusual year for CCOs, given the panoply of risks, the disruption to every organization, and devastating impact of the COVID-19 pandemic. CCOs were forced into a new environment where health and safety issues, along with remote working arrangements raised a number of new risks that had to be addressed. CCOs played an important role in reassuring employees, shareholders and other stakeholders in the community.
Europe, Middle East and Africa Investigations Review 2020
Fighting corporate crime and compliance defence in the Czech Republic
In summary
Inspired the US Department of Justice’s (DOJ), non-binding internal guidelines for public prosecutors were issued in September 2018 (Czech CMS Guidelines). A slightly updated version of the Czech CMS Guidelines was published in November 2020. Both guides are comparable in quality and level of detail and a company will set-up an equally effective compliance management system following either of them. The major difference is the approach of the Czech prosecution authorities, which is considerably less predictable compared to DOJ’s. Czech prosecuting authorities are still struggling to understand the concept of compliance management systems and specially to apply it accordingly taking into account all the relevant specifics of the prosecuted company.