“As of Jan 1 I came off the Management Committee, I'm still on the Investment Committee, and I won't take new board seats as we sell companies.”
JA
James Andersen
Buyers and Builders ·
Compliance into the Weeds · New Fraud Section Guidelines
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Use new DOJ enforcement priority memo as a trigger to initiate a conversation with senior management, audit committee, and board about updated enforcement risks
“As of Jan 1 I came off the Management Committee, I'm still on the Investment Committee, and I won't take new board seats as we sell companies.”
“The board then comes up with a compliance committee ... within 90 days ... to show how they will hold senior management accountable”
“We have both an enforcement division and an audits division ... those have already proven to be pretty effective tools”
“In his first week, the president fired 17 federal inspectors general… reduced DOJ anti-corruption lawyers from 36 to two… SEC enforcement actions have fallen more than 90% this year.”
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