Ethics Anti-Corruption

News & Analysis as of

Tone At The Middle: Tone At The Top Is Important, But Tone At The Middle Is Also An Influential Driving Factor

We all know that “tone at the top” is a critical component of a successful compliance program — it’s mentioned as a hallmark in the Resource Guide to the U.S. Foreign Corrupt Practices Act and you see it in headlines, white...more

Are your sponsorship and hospitality controls enough to satisfy the FCPA? Maybe not

On May 20, 2015, the US Securities & Exchange Commission (SEC) settled an administrative proceeding with global mining /commodities producer BHP Billiton, resolving allegations that the company violated the books and records...more

Global Anti-Corruption Enforcement Trends Hit FIFA

Insights on the anti-corruption trends that contributed to the Fédération Internationale de Football Association (FIFA) scandal, and six essential characteristics of organizations whose cultures help prevent bribery and...more

Compliance: It Starts With A Village

A few weeks ago I had Mike Kenealy, COO of Insiders Integrity engage in a Q and A on “Just ‘Say No’ to Bribery but Prepare First. A Front Line Story,”. Last week, Mike shared with me a pro-bono project that he had sA few...more

Can you Certify Anti-Corruption Compliance?

Today’s Q & A is with Philippe Montigny, CEO, Ethic-Intelligence - Q: Hello Philippe and thank you for participating in this Q and A. Having been invited to your own “Experts Corner,” it is a pleasure to engage with you...more

International Anti-Corruption Day

Today is International Anti-Corruption Day. This occasion is a good opportunity to think about whether your organization has sufficient systems, policies and controls in place to ensure ethical and responsible business...more

FCPA Compliance and Ethics Report-Episode 110-interview with Jonathan Armstrong [Video]

In this episode I visit with Jonathan Armstrong a partner in Cordery in London. He visits with me about his new firm, the equity investment of Lexis/Nexis in his firm and some of the trends he sees in cross-border...more

FCPA Compliance and Ethics Report-Episode 105-interview with Barry Vitou [Video]

In this episode I visit with Barry Vitou, one-half of the bribery act.com guys. We discuss the current state of anti-corrruption prosecutions in the UK, the SFO and self-disclosure under the Bribery Act. ...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Five Most Common Weaknesses in Anti-Corruption Compliance Programs

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Designing Cost Effective Risk Assessment Programs May 21, 2014 [Video]

The foundation of every anti-corruption ethics and compliance program is a risk assessment. It is important to design and implement a process to conduct an initial risk assessment, to update the risk assessment, and to ensure...more

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

Will TRACE Certify the World?

Aaron Hernandez, former of New England Patriots tight end, was indicted for murder this week, allegedly killing a man for spilling his drink at a bar. But fatal disputes originating in taverns are not anything new as on this...more

EU Institutions: More Talk Than Action On Anti-Corruption Efforts?

Last month, anti-corruption watchdog Transparency International released its first-ever corruption and integrity risks report. Titled “EU Integrity System (EUIS) Report” the report focused specifically on EU institutions,...more

The Red Headed Stranger And The Arachnys Open Data Compass

Today we celebrate one of the great state of Texas’ greatest gifts to the musical world – the red headed stranger, Willie Nelson, who was born 29th April 1933. ...more

The FCPA Compliance and Ethics Report-Episode 66, Visit with Virna De Palma from TRACE [Video]

In this episode I visit with Virna De Palma,Senior Director, Global Strategy & Communications at TRACE International, Inc.. She talks about some of the services which TRACE offers and details a new and exciting scholarship...more

What Is The Role Of An Apology In Anti-Corruption Enforcement?

What is the most famous apology in literature? Plato’s Apology for Socrates certainly is in the conversation. In addition to presenting Plato’s views on his teacher, it is believed to be the most authentic account that has...more

2014 Trends: #2 Navigating the Myriad Anti-Corruption and Bribery Laws

Earlier last week we began discussing the top ten trends in ethics and compliance we identified for 2014. Third party risk as the ethics and compliance “Achilles heel” dominated the conversation in our first trend. In this...more

My Favorite Blog Posts From 2013

One of the best things about the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and other anti-corruption practice areas is the top notch quality of commentators. While Mike Volkov regularly derides the FCPA paparazzi...more

Keep Your Hand On The Control

I am continually amazed at the seemingly disparate current events which provide tangible lessons for the compliance practitioner. In an article in the New York Times (NYT), entitled “Hearings on San Francisco Crash Set to...more

It’s The Great Pumpkin: Lessons In Process Validation And Oversight

Today is Halloween and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts gang, who...more

FCPA Compliance and Ethics Report-Episode 15-GSK in China: a Game Changer in Compliance [Video]

In this Episode 15, I am interviewed by Mary Flood about my recent eBook, GSK in China: a Game Changer in Compliance. I believe that this case will be one of the most significant international anti-corruption developments in...more

The Harvest Moon Will Shine A Light On Compliance

The Harvest Moon is generally considered to be the full moon closest to the Autumn Equinox; the day in the fall when night and day are most equal in length. In folklore, the Harvest Moon was a symbol of fruitfulness allowing...more

Astros Swept Again – Is A China Sweep Coming Next?

What is a sweep? It is certainly a well-known and relevant term in the sporting world....more

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