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Mid-Year FCPA Report, Part II

Today, I continue my look at what I think were some of the most significant highlights from the first half of 2014 relating to the Foreign Corrupt Practices Act (FCPA). Yesterday, the focus was on corporate and individual...more

Mid-Year FCPA Report, Part I

As we are now past the halfway mark of 2014, I thought it might be a good time to look at the year in review, so over the next couple of days, I will be reviewing what I believe to be some issues and developments to the...more

How A Failure to Set Tone-at-the-Top Led to a Fractured Vertebra

What does ‘Tone-at-the-Top’ mean to any anti-bribery or anti-corruption program? Conversely, what if management says to do the right thing but only judges employees on their sales; what is the message that only ‘Talking The...more

Anti-Bribery and Corruption Compliance Practices

Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

The Network News

Fraud Index Released-Startling Findings - A survey of more than 1,400 organizations worldwide revealed startling 4th quarter results on fraud trends for 2013. The Fraud Reporting Percentage (FRP), which measures fraud...more

Coolness in Being the Bad Guy? Eli Wallach and GSK

Eli Wallach died Tuesday. For my money, he was about the coolest bad guy out there. Not tough like Lee Marvin, just cool. My favorite Wallach roles were as Calvera in The Magnificent Seven and as Tuco in The Good, The Bad and...more

FCPA Compliance and Ethics Report-Episode 70-World Cup Report-Part III [Video]

In this episode, the World Cup Report Part II. Mike Brown and I continue our exploration of compliance lessons from FIFA and the 2014 World Cup. We discuss why following the money is so critical, then analyze the US tie with...more

The Magna Carta and Scrutiny of Your Compliance Program

Sunday, June 15 was Father’s Day so for all us fathers out there, it was our day and I hope that you enjoyed and cherished it. It was also the anniversary of what I believe was one of the greatest achievements in Anglo...more

FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor [Video]

In this episode I welcome back the FCPA Professor who gives his views on the Esquenazi decision, his recent book and his upcoming FCPA Institute....more

Semper Fi and Compliance-Leadership Lessons from the Marines

Ever wonder where the US Marine Corp got its nickname of ‘hellhounds’? It came courtesy of the Imperial Germany Army from a battle that took place in the month of June 1918, the Battle of Belleau Wood....more

Survey: Anti-Corruption Laws Have Major Impact on Corporate Compliance Policies

With over $1.5 billion in fines assessed by the U.S. Securities and Exchange Commission for violations of the Foreign Corrupt Practices Act (FCPA) since 2010, corruption concerns are playing a larger role in corporate...more

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II [Video]

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....more

Whither FIFA?

On this day in 1942, the Battle of Midway, one of the most decisive US victories against Japan during World War II, began. During the four-day sea-and-air battle, the outnumbered US Pacific Fleet succeeded in destroying four...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

What Does an Effective Compliance Program Look Like? – The Regulators Perspective

What does an effective compliance program look like? Is it one that follows the Ten Hallmarks of an Effective Compliance Program as set out in the 2012 FCPA Guidance?...more

Building a Next-Generation Anti-Bribery & Corruption Compliance Program

Global companies face unprecedented third party risk in today’s landscape — third parties are involved in 90% of Foreign Corrupt Practices Act (FCPA) cases, and more companies are under investigation than ever before in the...more

Maybellene And The 2014 Anti-Bribery And Corruption Benchmarking Report

Today, we celebrate an event, which is not ‘the day the music died’ but one that might properly be called one of the seminal moments in the creation of Rock N’ Roll. On this date in 1955, Chuck Berry recorded his first song,...more

Compliance Hiring Practices Under The FCPA

Hiring practices under the Foreign Corrupt Practices Act (FCPA) are not often given much thought or widely discussed. They have come up for discussion more recently because of the issues surrounding the hiring of sons and...more

Hitting The Ground Running – Your First 100 Days As A New CCO

The first 100 days. Franklin D Roosevelt’s (FDR’s) first term is the standard by which all other Presidents are measured for their first days in office. Why? ...more

Tales From The Crypt - Rule No. 9 - Don’t Let The Revolving Door Hit You On Your Way In (And Out)!

Ed. Note-today we continue the series from the Two Tough Cookies. Today, they have a cautionary tale about not letting that revolving door hit you... One of the toughest things to gauge about a potential employer is...more

Gifts, Travel And Entertainment Under The FCPA – Part I

One of the first thing that many companies will try to put in place is a gifts, entertainment and travel policy when looking at an overall compliance program. I find the reality to be that not only is this one of the more...more

Nursery Rhymes, A Chinese Proverb, The HP FCPA Enforcement And The Myth Of The Rogue Employee

As my friend and colleague Jay Rosen is want to remind us, he continually learns much about compliance and ethics from his Kindergarten-aged daughters. I submit that you need only look to children’s nursery rhymes in the...more

Post Traumatic Settlement Disorder

The rigor and stress of an extensive corporate internal investigation is over. You’ve helped your client determine the scope of wrong-doing, take actions against wrong-doers, calculate the damages/amount of the fraud, fix...more

Tales From The Crypt - Rule No. 7 - Actions Speak Louder Than Words

Ed. Note-I inadvertently ran Tale From The Crypt, Rule No. 8 out of order, so today we present Rule No. 7, which reminds us that Mom was right, actions do speak louder than words... This Tale from our Crypt reminds us...more

Mickey Rooney And The 90 Cent Solution

We begin today with a word on the death of Mickey Rooney. Rooney’s career, spanning nearly 90 years was certainly was from a different era. He was short of stature and long in his number of marriages but as Bob Lefsetz noted...more

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