News & Analysis as of

Healthcare Ethics and Compliance Program Requirements

The Affordable Care Act included a mandate that medical service providers and suppliers enact compliance programs as a condition of participating in federal health care programs. (The ACA also set a deadline of March 23,...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

FCPA Compliance and Ethics Report-Episode 73-World Cup Report-Part V [Video]

In this episode, Mike Brown and I look at the assessment of 'Tone at the Top' from the perspective of the Brazil/Colombia World Cup final and the horrific injury to the Brazilian striker Neymar. ...more

FCPA Compliance and Ethics Report-Episode 72-interview with Michael Rasmussen [Video]

In this episode of the FCPA Compliance and Ethics Report, I interview Michael Rasmussen, the GRC Pundit. As the man who coined the phrase 'GRC' Michael is one of the country's top GRC experts. He talks about the recent OCEG...more

CCOs Need To Adopt Their Own Code of Conduct

As CCOs become a key player in the corporate governance world, ethics and compliance leaders are developing principles to be used by compliance pofessionals. It is a natural process that reflects the growing...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

FCPA Compliance and Ethics Report-Episode 69-Joe Oringel, co-founder of Visual RiskIQ on Transaction Monintoring [Video]

In this episode, I visit with Joe Oringel, co-founder of Visual RiskIQ. Joe talks about transaction monitoring and the tool that his company has developed to assist companies with FCPA compliance. ...more

Why BoDs and CEOs Need Workplace Harassment Training Too: American Apparel’s Board and CEO Violated Their Own Code of Ethics

I was driving home Wednesday evening, listening to the news on the radio, when I heard the story about Dov Charney, the CEO of American Apparel, being fired by the company’s board of directors. According to that story and...more

Consent is a Process, Not a Piece of Paper: Practical Advice for Documenting Conflict Waivers

Is it possible to practice law anymore, no matter your practice setting, without drafting or reviewing waivers of conflicts of interest from time to time? For those of us old enough to remember, back in the last century,...more

How Does Your Ethics & Compliance Training Measure Up?

For the last five years, NAVEX Global has been proud to provide the industry’s best and most statistically accurate hotline benchmarking data. Our annual reports are a trusted resource for ethics and compliance officers,...more

SEC’s enforcement division cracking down on misconduct

In a recent interview with the director of the Securities and Exchange Commission’s enforcement division, Andrew Ceresney, he noted that the biggest challenge they face is seckeeping up with the “increased complexity of […]...more

FCPA Compliance and Ethics Report-Episode 68-Neil Swidey, author of Trapped Under the Sea [Video]

In this episode of the FCPA Compliance and Ethics Report, I visit with Neil Swidey, author of Trapped Under the Sea. Neil connects Safety, Management and compliance in talking about his compelling new book. ...more

Fixing a Company’s Ethics and Compliance Culture

We all have been following the “turn around” projects at some of the big companies — Walmart, Morgan Stanley, SNC-Lavalin, just to name a few. Changing a corporate culture, even under the Sword of Damocles, can be a...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

Code of Ethics Training is Worth it! Five Measurable Components of Corporate Culture

This may be my final post-Compliance Week update – I haven’t decided yet. But I’m excited to share thoughts about another session that had some great ideas and discussion. It was about the notion of measuring corporate...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

FCPA Compliance and Ethics Report-Episode 65-World Cup Report-Part I [Video]

The FCPA Compliance and Ethics Report, Episode 65 is out. In this episode, I begin a 4 part World Cup series with Mike Brown, Managing Director of Infortal. In this episode we discuss bribery and corruption of referees and...more

Failure to Plan is Planning to Fail: Keys To Raising Employee Awareness of Ethics & Compliance Programs

Between sessions at last week’s Practicing Law Institute conference in New York, I had several conversations with compliance officers about their ethics and compliance program challenges. The common theme among the challenges...more

Citibank: Multiple Failure of Compliance as the Hammer Drops

What is the cost of the failure to perform appropriate due diligence on a regular basis? What red flags should you look for when considering doing business with a customer...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

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I [Video]

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...more

One person’s gift, another person’s bribe: The challenge of giving gifts in China, Part 1

It was the week before Chinese New Year. The financial year had ended weeks earlier and unpaid invoices had made a dent in the annual performance of the small family business. For months, the foreign husband, a co-owner of...more

The “Coffee and Naps” School of Business Ethics Training: Part 2

In Part One of this series, we discussed how to complete an ethics audit and culture snapshot. Today we’re going to explore the importance of your relationship with your CEO (or Chief Culture Officer) in building an ethical...more

Why Not Use Ethics Training as a Feedback Mechanism to Improve Culture?

I read this great blog by Ken Reda on the Profit Advisory Group site. The blog “Is Your Company Culture Costing You Money?” is fascinating. Those of you who regularly read my blogs (thanks!) know I’m all about company...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

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