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 Brazilgave credit for the Company's hotline which produced the tip that led to the investigation.
Welcome to the 2010 Missteps Archive!
Back to Learning From Others' MisstepsMarch 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.