Ethics Compliance

Culhane Meadows’ attorneys provide counsel to private sector clients as they navigate through a myriad of ethics compliance rules when doing business with government agencies or contractors, including but not limited to:

Federal Acquisition Regulation Ethics Compliance
Large Federal contracts require a written Ethics Code modeled on Federal Executive Branch Ethics Program addressing: conflicts of interest, gifts, recruitment, Federal employee employment and post-employment restrictions, training, hotline, and enforcement. Also requires: Chief Compliance Officer to report to VP or CFO; background checks of officers, directors, and partners; and Federal audits of training and program effectiveness with access to records.  Violations can result in suspension, debarment, and or False Claims Act prosecution regarding conflicts of interest/bribery/gratuities (gifts).

Foreign Corrupt Practices Act Compliance
Gifts defined as anything of value given to Foreign Officials (interpreted broadly). Applies if place of business is located in US or securities are regulated in US. Big issue: foreign facilitation payments.

UK Bribery Act Compliance
Bribes are defined to include gifts, entertainment, travel, and lodging. Law applies to any business in the UK or close connection to the UK. Corporate liability exists for failing to prevent bribery.

FINRA (Financial Industry Regulatory  Authority) Ethics Rules Compliance
Ethics Program is required addressing: gifts, conflicts of interest and COI reporting, outside compensation limits and reporting, product recommendations, Financial Condition Balance Sheet disclosure, travel reimbursement limits and disclosure, and Compliance Supervisor responsibilities.


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