Chief Compliance Officers The Foreign Corrupt Practices Act

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Tribute to Dr. Jannetta and Improvisation in Compliance

It is rare you are able to write about someone who directly changed the quality of your life. Rarer yet that you did not know about him, only what he created, until you read his obituary. That happened to me recently when I...more

Who Can Fire a CCO?

There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more

Shakespeare Week – Part III: Much Ado About Nothing and Incorporation of Social Media into Your Compliance Program

How does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on...more

Shakespeare Week – Part I: Henry IV, Part II – Lawyers and Compliance

What is the most famous line in Shakespeare about lawyers? That is an easy one because lawyer-haters across the world (and lawyer-lovers as well) know it – First thing we do is kill all the lawyers. It comes from Henry IV,...more

Big Data in a Best Practices Compliance Program, Part III-Visualization

Today I continue my exploration of big data in a best practices Foreign Corrupt Practices Act (FCPA) compliance program. Yesterday, I considered how you might use big data in a best practices compliance program. Today I want...more

Big Data in a Best Practices Compliance Program, Part II

Today I continue my exploration of big data in a best practices Foreign Corrupt Practices Act (FCPA) compliance program. Yesterday, I considered what big data is and some ways to think about it. Today I want to move into some...more

Big Data in a Best Practices Compliance Program, Part I

I have founded several podcasts, one of which is Compliance into the Weeds, where Matt Kelly joins me each week take a deep dive into the weeds of a compliance related topic. As many of you know, Kelly is the former...more

New DOJ Guidance and FCPA Pilot Program – Part IV: Impact

This week I have been exploring the implications of the Department of Justice (DOJ) announcement last week of a new program Pilot Program around Foreign Corrupt Practices Act (FPCA) enforcement, together with the document,...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

[Webinar] Practical Guidance for U.S. Companies Expanding into Europe Through Commercial Arrangements - April 6th, 9am PST, 11am...

Please join us for a discussion focused on providing practical guidance to U.S. multi-national companies looking to grow their businesses in the European market. Panelists will consider various types of commercial...more

Prog Rock Week – Part III: Watcher of the Skies and Staying Sane as the CCO

As noted by Dan Epstein, in the Rolling Stone article “50 Greatest Prog Rock Albums of All Time”, the Genesis album Foxtrot was arguably the band’s first great album. The album “took the eccentric worldview and symphonic...more

Prog Rock Week – Part II: Karn Evil 9 and Kaizen for Compliance

Yesterday, I began Prog Rock Week with a tribute to Keith Emerson. So sit back my friends and enjoy the show that never ends, as I explore my favorite prog rock albums and cuts. Today, I will further honor Emerson and his...more

DOJ Fraud Section Chief and Compliance Counsel shed light on compliance program evaluations: the four areas of inquiry

There has been quite a buzz since the Department of Justice announced last year that it had appointed a compliance counselor to aid prosecutors’ evaluation of compliance programs and would focus on individual culpability for...more

The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance

The U.S. Department of Justice announced last week that Olympus Corporation of the Americas (OCA) agreed to pay $646 million to resolve three cases relating to its longstanding practice to bribe doctors and hospitals in the...more

Foundations of Texas and the ROE from a Best Practices Compliance Program

On March 2, we here in the great state of Texas celebrated the 180th founding of our Republic, which occurred in 1836 with the aptly named settlement of Washington-on-the–Brazos, where delegates signed the Texas Declaration...more

The VW Scandal: Crisis and the CCO

One of the areas where my thinking has evolved in the compliance arena is around the area of reputational damage. Of course commentators, such as Andrea Bonime-Blanc, have written and spoken about preventing damage to a...more

VimpelCom Settles FCPA Case – Part III

Today, I continue my exploration of the lessons to be learned from the VimpelCom Ltd. (VimpelCom) Foreign Corrupt Practices Act (FCPA) enforcement action. While it is clear that the company and its Uzbeki subsidiary, Unitel...more

Communicating Culture Outside the US – Part 2

Yesterday, I began an exploration about some of the issues around communicating corporate culture to business units located outside the US and away from the corporate office. This series is based on a recent article in the...more

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

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