Chief Compliance Officers, FCPA

Improving Your Anti-Corruption Training Program

by Michael Volkov on 5/8/2013

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

by Thomas Fox on 4/25/2013

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

The Danger Of FCPA “Proactive” Investigations

by Michael Volkov on 4/22/2013

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

SEC Highlights Compliance and Ethics for Broker-Dealers

by David Smyth | Brooks Pierce on 4/11/2013

On Tuesday the SEC held a National Compliance Outreach Program for Broker-Dealers at an open meeting at its D.C. headquarters. The first panel – titled The Role of Compliance and Ethics – was nominally targeted to...more

Why Eat Your Words When You Can Eat a Peach?

by Thomas Fox on 4/9/2013

Taken to the woodshed or when should a company have to eat its own words? Remember when President Reagan’s Director of the Office of Management and Budget, David Stockman, was ‘taken to the woodshed’ by White House Chief of...more

Three Compliance Interviews on April 3

by Thomas Fox on 4/4/2013

I attended the Dow Jones Global Compliance Symposium over the past couple of days. It was a great conference and kudos to the entire Dow Jones team for putting on a truly memorable event. Day 2 had some interesting speakers...more

Monitoring Of Third-Party Agents And Distributors

by Michael Volkov on 4/3/2013

Try to imagine what DaVinci said to himself when he painted his last brush stroke on the Mona Lisa. Or consider what Tolstoy muttered to himself when he put down his pen after writing the last word of War and Peace....more

The Truth Behind Gifts, Meals And Entertainment Enforcement

by Michael Volkov on 3/29/2013

It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more

Facilitation Payments: An Intractable Problem?

by Michael Volkov on 3/26/2013

It sounds easy on paper. A company announces that it has banned all facilitation payments. It is a worthy goal. It sounds admirable. The FCPA permits facilitation payments. The UK Bribery Act prohibits facilitation...more

Don’t Spread Your Compliance Program Too Thin

by Thomas Fox on 3/25/2013

“You do not want to be spread too thin”. When I heard that phrase a light bulb went off inside my head. It was uttered to me by Jan Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he meant by the...more

Anti-Corruption Compliance Check-Ups

by Michael Volkov on 3/11/2013

The Justice Department’s message is getting through. The two-fisted strategy of aggressive enforcement and public cajoling on the importance of compliance is being heard by the business community. The Justice Department and...more

A Roadmap for Audit Committees in Meeting the Challenges Posed by Enhanced Regulatory Scrutiny Under the Dodd-Frank Act

by N. Richard Janis, Jennifer Sincavage | Manatt, Phelps & Phillips, LLP on 2/25/2013

Audit committees must aid management in navigating an increasingly complex regulatory framework. Two recent developments arising from the passage and implementation of the Dodd-Frank Act have led to further challenges for...more

Tribute to Stan The Man and 11 Rules for Compliance Success

by Thomas Fox on 1/21/2013

Today we honor Stan ‘The Man’ Musial who played 22 seasons for the St. Louis Cardinals (1941–1963) who passed away on Saturday. Musial was a record 24-time All-Star selection and is widely considered to be one of the greatest...more

How to Reach Your Audience in Compliance Training – The Use of Charisma

by Thomas Fox on 1/18/2013

One often hears or reads about complaints that compliance training is dull, nay even boring. I mean, how many times can you expect someone to be lectured to on the riveting subject of the Foreign Corrupt Practices Act (FCPA)...more

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

by Thomas Fox on 1/16/2013

One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more

The Compliance Officer’s Crystal Ball

by Michael Volkov on 1/9/2013

In the last five years, law firms and companies have aggressively added resources and capabilities to respond to increased FCPA enforcement and compliance needs. Outside counsel have established practice areas dedicated...more

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Chief Compliance Officers › The Foreign Corrupt Practices Act

Improving Your Anti-Corruption Training Program

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

The Danger Of FCPA “Proactive” Investigations

SEC Highlights Compliance and Ethics for Broker-Dealers

Why Eat Your Words When You Can Eat a Peach?

Three Compliance Interviews on April 3

Monitoring Of Third-Party Agents And Distributors

The Truth Behind Gifts, Meals And Entertainment Enforcement

Facilitation Payments: An Intractable Problem?

Don’t Spread Your Compliance Program Too Thin

Anti-Corruption Compliance Check-Ups

A Roadmap for Audit Committees in Meeting the Challenges Posed by Enhanced Regulatory Scrutiny Under the Dodd-Frank Act

Tribute to Stan The Man and 11 Rules for Compliance Success

How to Reach Your Audience in Compliance Training – The Use of Charisma

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

The Compliance Officer’s Crystal Ball

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

Expand Your Reach