Is the SEC putting a hurt on compliance programs?

In my most recent column in the SCCE’s Compliance & Ethics Professional magazine (see page 2 of PDF) I look at the SEC’s new aggressive approach to charging parent companies for the offenses of their subsidiaries, and consider what unintended and undesirable effects on C&E programs this might have.

And for more information on the “why” and “how” of C&E programs for JVs, subsidiaries and other corporate affiliates, here  is a link to an eight-part series in the FCPA Blog by Rebecca Walker and me on “Compliance for the whole family.”