Welcome to the 2010 Missteps Archive!

Back to Learning From Others' Missteps

  • March 2010 - Fox Insurance Company - Loses its Medicare Part D drug contract, in part for failure to meet its Compliance Program requirements under the contract. Lesson: Don't wait until after the investigator arrives to hire a Chief Compliance Officer.

  • November 2010 - Noble Corporation receives credit in its Foreign Corrupt Practices Act settlement with the Department of Justice for the existence and features of its preexisting Compliance Program. Lesson: An ounce of prevention may save pounds (or dollars) in the event of a misstep. Similarly - August 2010 - DOJ's resolution of an FCPA claim against Universal Brazil gave credit for the Company's hotline which produced the tip that led to the investigation.