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The Mummy and Internal Controls in Locations Outside the US – Part III

Today we celebrate Hammer Film’s version of The Mummy. This was the first film that the Hammer studios made under a license agreement with Universal Pictures, the holder of the copyright of its classic monsters from the 1930s...more

Implementing compliance programme at the emerging markets of the former Soviet Union

Ed. Note-today we have a guest post from Timur Khasanov-Batirov, Chief Compliance Officer at DTEK and Co-Chairman at Compliance Club of the American Chamber of Commerce in Ukraine. It will be a challenge. I mean to...more

I Need an Automated Policy Management System: Should I Build or Buy?

As many ethics and compliance professionals know all too well, effective management of even a single policy can require significant effort. Managing and coordinating the work of subject-matter experts, reviewers, and...more

Yes, Compliance Programs Still Matter

On September 29, 2014, we asked: “Does a Compliance Program Matter to U.S. Antitrust Enforcers?” After concluding that compliance programs still provide tangible benefits, we offered five factors that companies should...more

Steve Bartman and Internal Controls Outside the US, Part II

Today, we note that 11 years ago, Steve Bartman entered the Chicago Cubs Hall of Infamy. For every baseball fan, if there was ever a but for the grace of God, go thee moment the sad saga of Bartman is it. The Chicago Cubs,...more

Government's Message to Corporate America — "We Want Your Whistleblowers!"

On September 22, 2014, the Securities and Exchange Commission's (SEC) Office of the Whistleblower announced that it had issued a $30 million bounty payment to a foreign whistleblower. This award is more than double the...more

Reflecting on the E.U. Ethics & Compliance Landscape: One Year After Opening Our U.K. Office

The growing shift in the E.U. away from piecemeal ethics and compliance programme components and towards a more comprehensive approach is an important and exciting evolution to witness....more

Ringo, Sir Paul and an Effective Compliance Program

Sometimes the universe converges in ways that are beyond my simple comprehension. This past weekend was one of them. It began a few months ago when I saw an advertisement from StubHub that showed Ringo Starr playing in...more

Tribute to Jim McGrath

Ed. Note-Jim McGrath died this week. He was a good friend and a trusted colleague. My thoughts are with his wife, sister and her family and his parents and the rest of us who were privileged to know Jim. ...more

Don’t Bore your Board: Seven Tips for Delivering an Engaging Ethics & Compliance Board Training Experience

If you are like most compliance officers, the thought of training your board on compliance risks may make your heart start beating just a little faster—and the task can quickly start to seem insurmountable. After all, it’s...more

Compliance Challenges: When the Almighty Dollar Rules

Chief Compliance Officers have to recognize one immutable fact – if a company does not make money, compliance does not matter. I know this is hard to fathom but a company’s purpose is to make money. The issue boils down to an...more

5 Halloween Office Celebration Risks To Address In Your Code Of Ethics Training

Halloween is one of my favorite holidays. For one day out of the 365/366 days of the year, everyone has the opportunity to be anyone or anything they want to be. It’s a blast. Over the last few years, I’ve been “your mom”, a...more

Chief Compliance Officer as Chief Persuasion Officer

The roles of a Chief Compliance Officer (CCO) can be many and varied but one role of any successful CCO is that of Chief Persuasion Officer (CPO). I say this because it is often the case that the most a CCO has in his or her...more

An ethics and compliance program in seven steps

Establishing compliant and ethical behaviour among the masses, and regulating against non-compliance is a big step in the fight against fraud and abuse. All organizations have their own unique plan in the running of their...more

FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics [Video]

In this episode I interview doctoral candidate Karen Schuder on her research into the teaching of business ethics. ...more

Creation of Yosemite and Putting Compliance at the Center of Strategy

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for...more

Ireland Takes Big Step in Protecting Whistleblowers

Earlier this year, the Protected Disclosures Act 2014 was enacted in Ireland to protect whistleblowers across all sectors of the Irish economy. Transparency International Ireland has lobbied for whistleblower legislation in...more

Boost Your Ethics and Compliance Training Efficacy: Borrowing from the Broken Window Theory to Prevent Unethical Behavior from...

The “broken window theory” is a social science or criminology theory that essentially states maintaining physical urban settings in good order will stop vandalism before it occurs. When Rudy Guiliani became mayor of New York,...more

Discipline and Rigor in Your Internal Controls

In a recent New York Times (NYT) Op-Ed by David Brooks, entitled “The Good Order”, he discussed how routine can lead to creativity. He cited to the example of three well-known authors whose habits included the following....more

How To Strengthen Your Ethics And Compliance Policy Management

People say that hindsight is 20/20. I’d say from my experiences its true. If only we could have 20/20 vision before an incident occurs, think of all the heartaches and headaches we could avoid. It would be especially helpful...more

FCPA Compliance and Ethics Report-Episode 95-interview with Scott Killingsworth on Private to Private Compliance Solutions [Video]

In this episode I visit with Scott Killingsworth, partner at BryanCave on his thoughts around the compliance solutions found in private-to-private compliance obligations. ...more

TNG Premiers and Internal Controls for Gifts in a Best Practices Compliance Program

This week, 27 years ago, Star Trek – The Next Generation (TNG) made its television debut. Rarely has there a follow up to a beloved original series (Star Trek – The Original Series (TOS)) that is equally treasured by fans. ...more

West Side Story and GSK In China – Board Oversight and Tone in the Middle

Yesterday, I celebrated the anniversary of one of America’s cultural lows. But today, I am extremely pleased to open with exactly the opposite, that being one of America’s greatest gifts to the performing arts....more

AB1825 Training In 2015: “Nudging” Employees To Do The Right Thing

What factors go into decision making? Would you argue that how a situation is framed impacts how you react? Of course. Let’s consider the following situation, and apply the same logic to improve our AB1825 Training...more

Important Employee Values: Integrity and Trust

I have urged compliance professionals to avoid scare-tactics as a way to enhance their importance in the corporate organization. It is too easy to run around and spread fear about the importance of compliance to prevent a...more

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