Orchid Blog
Educational Updates for FFLs
Eli Lilly’s Remedial Efforts for FCPA Compliance – After the Fact
Yesterday, we covered the news of the $29 million plus settlement entered into by Eli Lilly and Company to stave allegations brought by the Securities and Exchange Commission for violations of the Foreign...
Eli Lilly and Company Settles Big After a Multi-Year Missed Opportunity for FCPA Compliance
On December 20, 2012, Eli Lilly and Company was charged by the Securities & Exchange Commission with multiple violations of the Foreign Corrupt Practices Act (“FCPA”) for events which occurred over a...
Eye on the Hill – a Return of the Federal Assault Weapons Ban?
Back in 1993, then House Representative (now Senator) Charles E. Schumer from New York was the primary sponsor of what became known as the “Federal Assault Weapons Ban” (Title XI, Sub. A of the larger...
How Compliance Equates to a Corporate Culture of Caring
How Compliance Equates to a Corporate Culture of Caring Recent testimony from expert witnesses on compliance at a UCLA chemistry lab in a fire that killed a 23-year old staff research assistant serves as an...
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...
