2010+Missteps

=//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.====