Chief Compliance Officers The Foreign Corrupt Practices Act

News & Analysis as of

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the...more

Economic Downturn Week, Part II – The Golden Gate Bridge and Employment Separation – Hotlines and Whistleblowers During Layoffs

I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more

On the Oregon Trail: the BHP Enforcement Action and High-Risk Hospitality

The settlers who took off on this Great Emigration on the Oregon Trail did not have anything in the way of a road map. Fortunately for the modern day anti-corruption compliance practitioner, you do have road maps that can...more

4 Questions to Ask When You Learn of Potential FCPA Violation

You can add this blog posting to my tagged category – “profound grasps of the obvious.” If you are brave and willing to succumb to yet another in this series, please read on. Much has been written about how to conduct...more

Compliance Week 2015 Wrap Up

Compliance Week 2015 has ended. This year was the tenth anniversary of the annual conference and in many ways I found it to be the best one yet. Matt Kelly and his team put together a conference and experience, which was...more

FCPA Compliance and Ethics Report-Episode 160-Compliance Week 2015 Wrap Up with Mike Volkov and Jay Rosen [Video]

In this episode, Jay Rosen and Mike Volkov help me to wrap up the Compliance Week 2015 conference which just concluded in Washington DC. ...more

[Webinar] Mid-Sized Companies and Anti-Corruption: How to manage corruption risks with limited resources - May 28, 11:00 am EST

Instances of corruption can have a significant impact on a company’s finances and reputation. With international anti-bribery enforcement actions on the rise, it is essential for companies to implement an anti-corruption risk...more

Why Reputation Risk is Quickly Climbing the Ethics and Compliance Priority List, Part 3 | Beyond Compliance Training

So far in this series, we’ve discussed why companies are adopting a more public focus on ethics and compliance, how reputational risk can impact a company and its brand, and the first three elements of a five-part framework...more

A CCO Job Function: Managing Talent

Garo Yepremian died this past week. For anyone who grew up watching National Football League (NFL) games in the late 1960s or 1970s; this was a name quite familiar to you even if you had trouble pronouncing it. Yepremian was...more

FCPA Compliance and Ethics Report-Episode 159-Alison Taylor on the intersection of CSR and the FCPA [Video]

In this episode I visit with Alison Taylor of BSR about the organizational behavior issues around bribery and corruption and the intersection of Corporate Social Responsibility and the FCPA. ...more

DOJ Criminal Investigations: “Boiling the Ocean” and Other Fish Tales (Part II of IV)

The old maxim – “Justice delayed is justice denied” – is a powerful statement relating to our criminal justice system. A subject of a criminal investigation – corporate or individual — undergoes enormous stress from a...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

The Thrill is Gone: On the Intersection of CSR and the FCPA

Somehow it seems fitting that the legacy of BB King inform today’s blog post which is about the intersection of Corporate Social Responsibility (CSR) and anti-corruption laws such as the US Foreign Corrupt Practices Act...more

I Was An Irrational Compliance Calculator

In what might be described as a “companion guide” to my Ethikos article Does Compliance Need More “Darkside,” I had a chance to read Scott Killingsworth’s work in the same edition, The Irrational Calculator: Sales at the...more

FCPA Compliance and Ethics Report-Episode 158-Jeff Lurie on pre-acquisition M&A protocols [Video]

In this episode I visit with management consultant Jeff Lurie about his thought for your pre-acquisition protocol when evaluating a company for a merger or acquisition...more

Compliance Risk Logic’s Mastering Compliance in International Markets Conference

If you are in the Far East there is now a master conference centered around the top compliance practitioners in the region. Next month, from June 8-9, Compliance Risk Logic is putting on its a conference in Singapore,...more

April FCPA Compliance Digest | BONUS: Major Changes to Global Anti-Corruption and Anti-Money Laundering Legislation

Generally my second digest focuses heavily on FCPA compliance-related news, but so many interesting stories took place in April that I just really couldn’t limit myself. The FCPA news stories are right up front, but read on...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA [Video]

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Senn Interview, Part I – Investigations Under the FCPA

One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more

Making the FCPA "Reasonable"— Exceptions and Affirmative Defenses

So, we have covered the Foreign Corrupt Practices Act’s (“FCPA”) scope, but the FCPA anti-bribery provisions also contain certain exceptions and affirmative defenses. These exceptions and affirmative defenses attempt to carve...more

FCPA Compliance and Ethics Report-Episode 156-emergency podcast on Deflategate and the Wells Report [Video]

In the first emergency podcast Jay Rosen and I review (what we know) of the Wells Report into Deflategate. We consider the issues from a FCPA compliance practitioner perspective and what lessons may be learned from the...more

Ruth Rendell and Developing Better Compliance Solutions

Ruth Rendell died this past weekend. Along with Patricia Cornwell, she was one of the two greatest mystery writers for the past couple of decades. I thoroughly enjoyed her books which, as her New York Times (NYT) obituary...more

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose [Video]

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

Schlumberger OFAC Enforcement Action – A New Threat?

I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating...more

King Arthur Week – The Quest for the Holy Grail and Compliance Defense – Part V

We conclude our Arthurian themed week with the Holy Grail, which has fired the imagination of artists for millennia. What was the Holy Grail? According to Professor Dorsey Armstrong in her Teaching Company lecture series,...more

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