Chief Compliance Officers The Foreign Corrupt Practices Act

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Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Data Analysis Week – Part I: What is Data Analysis in Compliance?

This week I will begin a five-series exploring data analysis and how it can be used by the Chief Compliance Officer (CCO) or compliance practitioner to support a best practices compliance program under the Foreign Corrupt...more

Take It Easy – Ruminations on Corruption Scandals in International Sports

As I end my week’s exploration of the intersection of bribery and corruption in international sports, I have also ended a week of solid listening to The Eagles 1970s studio albums. In honor of Glenn Frey, I will also end this...more

How the Venetian Gondolier Informs Your Compliance Program

This is my final Travel Edition from Venice. If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to...more

The Year 2016 in Compliance

Greetings from Venice where my wife and I are spending the next few days so this blog post is my first Travel Edition of 2016. Last week I wrote about my thoughts on some of the significant Foreign Corrupt Practices Act...more

The Father of Texas and Leadership in Compliance

Today we celebrate leadership, which comes from a different place than we usually see. On December 27, 1836, the Father of Texas, Stephen F. Austin, died. Most people think Sam Houston was the father of this great state but...more

Applying Practical Strategies to Supply Chain Risk

Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball and...more

Phi Slama Jama and Leadership in Compliance

Guy V. Lewis died last week. For those uninitiated in college basketball, Lewis was one of the greats, coaching for over 30 years at the University of Houston. He went to the Final Four five times, alas though he did not win...more

Compliance Counsel Metrics – Part III: Program Evolution and Incentivizing Compliance

Today, we continue our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. These...more

Celebrate Compliance Week 2015

November 1-7 is Compliance and Ethics Week. I wanted to give you some ideas on how you might use this week’s designation to help bring the message of compliance and ethics to your organization. An oft-raised topic is how to...more

A Dash Home for the Ages – Using Start-Up Techniques to Further Compliance

Congratulations to the Kansas City Royals for winning the World Series on Sunday night. Watching a franchise that has never won such a championship, I can certainly understand the elation of a team that had not been to a...more

Homeland, Brazilian Clean Companies Act Guidance and the Need for Accurate Translations in FCPA Compliance

He used to work in the movie business so you might think the production crew of the Showtime series Homeland would just give him a call. After all he is fast becoming known as ‘the translations guy’ in the Foreign Corrupt...more

Promoting Antitrust Compliance – The Antitrust Division’s Subtle Shift Regarding Corporate Compliance: A Step Toward Incentivizing...

INTRODUCTION: A surprising feature of many corporate compliance programs is their limited emphasis on antitrust. Compliance efforts are a key feature of modern corporate governance initiatives, and it stands to reason...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Good-Bye to Maureen O’Hara and How to Drive Compliance into the DNA of Your Company

Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne. Testament to the fiery...more

Due Diligence and Risk Priorities (Part III of IV)

Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become...more

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

Getting Started on Due Diligence of Third Parties (Part I of IV)

This week I am posting a series on due diligence. There are basically two types of people. People who accomplish things, and people who claim to have accomplished things. The first group is less crowded. – Mark Twain...more

Evolving Best Practices in FCPA Compliance Training

As Houston, TX, is the epicenter of Foreign Corrupt Practices Act (FCPA) enforcement, most energy companies in my hometown have mature compliance programs or at least more mature than in other industries, which have not gone...more

Chief Compliance Officer as Enterprise Leader

One of the areas that a Chief Compliance Officer (CCO) must master is looking beyond their own compliance department to the company as a whole. CCOs must therefore lead their own compliance function but also lead with an...more

Foreign Bribery: The Inquiry Briefing Paper on the Senate into Australia's Foreign Bribery Scheme

The Commonwealth Senate Standing Committee on Economics is conducting an inquiry into the scope and effectiveness of existing Australian measures to address foreign bribery. It is due to deliver its report in July 2016....more

Compliance Connected – Line of Sight, Part II

Today I continue my exploration of the line of sight theory under which a Chief Compliance Officer (CCO) or compliance practitioner would have visibility across the lifecycle of a sales transaction so they could move from...more

Compliance Connected – Line of Sight, Part I

Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red Flag Group, at the SCCE...more

Dissecting a Bribery Violation: Two Important Questions to Answer

In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more

Alaska Day and Why Compliance Should Widen its Circle

Today we celebrate Alaska Day, traditionally celebrated on October 18th, for on that date in 1867, the US formally took possession of Alaska after purchasing the territory from Russia for $7.2 million, or less than two cents...more

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