Chief Compliance Officers The Foreign Corrupt Practices Act

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Defending parallel proceedings: key considerations and best practices

Parallel proceedings refer to two or more concurrent investigations or litigations arising out of a common set of facts. These proceedings can involve any combination of criminal, civil, or administrative authorities, as well...more

Tangled Up in Blue and Rethinking the Role of the Compliance Professional

Today, I conclude my tribute to Bob Dylan-Nobel Laureate, by discussing my personal favorite Bob Dylan song, Tangled up in Blue. The time shifts and jumps in the song have always resonated with me. Indeed, it is one of the...more

Monster Movie Month: Episode 2 – The Bride of Frankenstein and Upcoming Events

Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Good-Bye to Arnold Palmer and Revolutionizing Compliance

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

Wells Fargo Week: Part V – Compliance is the Answer

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

How Compliance Can Be Built to Succeed! An In-Depth Discussion with Donna Boehme PART 1 [PODCAST]

Donna Boehme is back on the Masters of Disaster® podcast to discuss what it takes for compliance to succeed. Donna often refers to the new approach for the architecture of Compliance 2.0. Fundamentally, Compliance 2.0 starts...more

Hallmark 9 – Continuous Improvement: Periodic Testing and Review

You should keep track of external and internal events which may cause change to business process, policies and procedures. Some examples are new laws applicable to your business organization and internal events which drive...more

Hallmark 7-Third-Party Due Diligence and Payments

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Hallmark 6-Incentives and Disciplinary Measures

The FCPA Guidance states, “In addition to evaluating the design and implementa­tion of a compliance program throughout an organization, enforcement of that program is fundamental to its effec­tiveness. A compliance program...more

Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

Compliance is a Business

Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance...more

A Trip to the Dentist for Some Compliance Insight

I had to go to the dentist yesterday. I went for what I thought was filling repair but I had somehow forgotten that it was a wisdom tooth removal and a filling repair. I know you are thinking either (1) why does someone his...more

England Wins 1966 World Cup and How to Lead a Change in Culture

Today we celebrate England’s sole World Cup win that occurred 50 years and two days ago on July 30, 1966. England, the World Cup host, beat West Germany 3-2 in the final. A crowd of 98,000 watched the game end in regulation...more

Are Compliance Officers at Financial Institutions Now in the Hot Seat for Fines?

Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more

Benchmarking Your FCPA Compliance Program

After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more

Securities Enforcement: 2016 Mid-Year Review

The Securities and Exchange Commission (the SEC or the Commission) brought over 400 enforcement actions in the first half of 2016 and is on pace to surpass its record of 807 enforcements actions in a single fiscal year, which...more

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

FCPA Compliance and Ethics Report-Episode 258-using data, data analytics and data analysis in your compliance programs [Video]

In this episode, I consider how a CCO can use data in a best practices compliance program. ...more

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

Tribute to Ali – The Greatest

The Greatest died this past Friday. There is only one man in my lifetime who earned that sobriquet and it was Muhammad Ali. Ali was the greatest sportsman in my lifetime and in 1999, he was named by the editors of Sports...more

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