Orchid Blog
Educational Updates for FFLs
Just What is a “Compliance Program?”
“Compliance program” is an often-used phrase that is easily repeated, even when the speaker has no clear understanding of what is being said. Compliance programs come up in the context of the multiple layers...
The Dollars and Cents of ATF Enforcement
With the annual Washington, D.C. budget negotiations underway, it’s a good time to rewind on the annual budget for the Bureau of Alcohol, Tobacco, and Firearms. Every fiscal year, the ATF is audited by...
The Auditor’s Dilemma – Getting the World To Listen
Auditing isn’t Investment Banking. It isn’t Strategy Consulting. We aren’t operating executives and we are rarely called upon to become CEO. It’s a tough profession that’s based on second...
Hewlett Packard and Self Reporting
Through their program guidelines, “Our Standards of Business Conduct – Building Trust Together,” Hewlett Packard sets out its “The Headline Test.” Quite simply, HP employees are instructed to ask “Would...
Step Right Up With your FCPA Violation
Step Right Up With your FCPA Violation Just a few days ago, we reported on our blog about the November 14 DOJ/SEC issuance of the 130-page guidance document titled “A Resource Guide to the U.S. Foreign...
Do You Have Your FCPA Game On?
On November 14, 2012, the Department of Justice and the Securities & Exchange Commission issued a joint guidance document on the 1977 Foreign Corrupt Practices Act. Some 35-years after passage of...