Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more
If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class. Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more
In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more
Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations. Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
The Houston Astros sign-stealing scandal filled out quite a bit last week with two significant new items. The first was an interview on the MLB Network by Tom Verducci, of disgraced Astros manager A.J. Hinch (Hinch...more
Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more
Corporate cultures do not operate in a silo or free from external influences. Yet again, another profound grasp of the obvious. Employees, managers and senior leadership all bring their own experiences, perspectives,...more
The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more
I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more
As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations(Antitrust...more
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more
When companies come under investigation, the DOJ will ask two principal questions about the company’s compliance function. The first question is “what was the state of the compliance program at the time of the improper...more
We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and...more
We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more
As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives. So, our kids start to speak up...more
The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more
The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more
I continue my exploration of how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more
What exactly does “corporate culture” mean? Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more
At some point, you must ask just how corrupt is an organization? What does the tone from top which says to make your numbers at all cost, translate to in operationalization? Unfortunately, we have seen yet another dramatic...more
Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more
Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles...more
Crimson flames tied through my ears... Rollin’ high and mighty traps... Pounced with fire on flaming roads... Using ideas as my maps... “We’ll meet on edges, soon,” said I... Proud ‘neath heated...more
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