The Harvest Moon Will Shine A Light On Compliance


The Harvest Moon is generally considered to be the full moon closest to the Autumn Equinox; the day in the fall when night and day are most equal in length. In folklore, the Harvest Moon was a symbol of fruitfulness allowing farmhands light to work on harvesting through the night or having a long roll in the hay, if one believes in the fertility enhancing properties of such events.

While I cannot speak directly to the latter, I can delineate some compliance related news on the former. As many of you might remember, I was privileged to have been part of the This Week in FCPA podcasts with Howard Sklar. Howard went off to the wide world of corporate compliance. This week I started a new compliance related podcasts series, The FCPA Compliance and Ethics Report, which can be found here. In this podcast series I will bring you the latest compliance, Foreign Corrupt Practices Act (FCPA), Bribery Act or any news related to other laws or topics regarding anti-corruption and anti-bribery. I will also be interviewing many of the leading compliance practitioners, compliance and ethics thought leaders, compliance product and service providers and others who impact the growing field of anti-corruption and anti-compliance. So if you are interested in being interviewed, give me a shout.

My first two podcasts are up. In Episode 1, I review the compliance related news of the summer, beginning with the GlaxoSmithKline PLC (GSK) matter and up through the revelations that JPMorgan Chase is being investigated for possible FCPA violations in regards to its hiring of the sons and daughters of Chinese government officials. In Episode 2, I interview Matt Ellis, founder of FCPAméricas blog. Matt discusses the new Brazilian anti-corruption law and relates how it may play out for US and other western companies in the upcoming rollout to the world’s grandest sporting events in the next three years, the World Cup in 2014 and the Summer Olympics in 2016.

Speaking of Matt Ellis, he has recently begun a site which is long overdue for the Spanish and Portuguese speaking compliance practitioner. Matt has added two well-known compliance practitioners as contributors to this new site. They are Carlos Ayres who specializes in anti-corruption and compliance issues, with a particular focus on Brazil and other regions of Latin America. He is an attorney with the law firm Trench, Rossi e Watanabe Advogados and co-chair of the Anti-Corruption and Compliance Committee of IBRADEMP (The Brazilian Institute of Business Law) in São Paulo. The second is Matthew Fowler, a seasoned FCPA attorney with over 12 years of experience as both outside counsel in leading law firms and internal counsel at a major defense company. He currently covers anti-corruption issues for the Inter-American Development Bank in Washington, D.C.

Beginning this month, the FCPAméricas Blog will regularly offer its new posts in Spanish and Portuguese. Matt’s translation partner for this new fabulous resource is the international translation company Merrill Brink. To get the ball rolling Matt has gone back and translated some of the most popular posts from his archives. So go over and check out the site. If your company has operations in Portuguese or Spanish speaking companies you might have your compliance team in those venues subscribe to this new resource.

If you are interested in how to manage your third parties in the FCPA context, please listen in on a webinar in which I am participating next week, entitled “Engaging With Confidence: Mitigating the Risk of Third-Party Relationships”. It is sponsored by Compliance Week and Datacert. This webinar will explore best practices for mitigating third-party risk, informed by latest government guidance and enforcement actions. Attendees will learn how technology can help prioritize and target due diligence efforts and facilitate ongoing monitoring to support a sustained state of compliance. The webinar is complimentary and will be held next Tuesday, September 10 at 1 PM CDT. Information and registration is available by clicking here.

Lastly, I am extremely pleased to announce that my most recent book, Best Practices Under the FCPA and Bribery Act, is now available on Kindle. The price is only $9.99 and is available at If you have not picked up the hard copy version, this is your chance for the electronic version. You can purchase the book by clicking here.

And last, but not least, pro-football is back…proving once again…there is a God.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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