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Implementing Compliance Incentives In Your Company

Several readers have asked why I have not written anything about the Houston Astros this year. The answer is two-fold. The first is that I really do not care. However, the more I thought about it, the real reason is that they...more

To Be a Criminal, You Have to Act Like a Criminal

Lawyers, compliance professionals and senior management at companies can be obsessive when it comes to the threat of criminal liability. Please do not get me wrong, I am not minimizing the risk of criminal prosecution, nor I...more

Asking Questions To Build Your Compliance Program

On this day in 1932 President Franklin D. Roosevelt (FDR) enacted the Civilian Conservation Corps (CCC) declaring a “government worthy of its name must make a fitting response” to the suffering of the unemployed....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

Tales From The Crypt - Rule 5: Red Eyes Can Definitely Affect Your Hearing

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

Tales From The Crypt - Rule 4: Cover Your Tracks

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

Tales From The Crypt: Rule 3 - Appearances Matter And May We Have The Envelope, Please.….Part II

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

FCPA Compliance and Ethics Report-Episode 45, Interview with Justice Ken Wise [Video]

In this episode of the FCPA Compliance and Ethics Report, I visit with Justice Ken Wise of the 14th Court of Appeals. We discuss contract drafting and interpretation, internal investigations and judicial ethics. ...more

Tales From The Crypt: Rule 3 - Appearances Matter And May We Have The Envelope, Please.….Part I

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

Avoid the Quick Fix: Addressing Government Contracting Ethical Breaches That Can Destroy A Business

For the last 15 years, the Foreign Corrupt Practices Act (FCPA) has garnered the most “compliance” attention by companies and the media due to the severe penalties associated with the bribing of foreign government officials....more

Something Is Rotten In Denmark Or Is It The Banking Industry?

“Something is rotten in the state of Denmark” is one of the signature lines from Shakespeare’s play Hamlet. I thought about that when I read a couple of recent articles in the New York Times (NYT), entitled “Questions Are...more

FCPA Compliance and Ethics Report-Episode 43, Interview with Neil Swidey, author of Trapped Under the Sea [Video]

In this episode, I visit with Neil Swidey, author of Trapped Under the Sea, who discusses safety, risk and leadership. ...more

FCPA Compliance and Ethics Report-Episode 42, Interview with Patrick Taylor of Oversight Systems on Transaction Monitoring [Video]

In this episode I visit with Patrick Taylor, President of Oversight Systems on transaction monitoring in a best practices FCPA compliance practice. ...more

Machiavelli For Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince by Niccolò Machiavelli. Just how evil do many people view the treatise? Consider that...more

Remember The Alamo: Analogy For Compliance Officers?

Today is the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, when Texas declared its independence from Mexico...more

FCPA Compliance and Ethics Report-Episode 40, Interview with Adam Turteltaub [Video]

In this episode I visit with Adam Turteltaub, from the SCCE. Adam has worked in the compliance space for over 10 years and has seen the increased awareness and acceptance of compliance. He also discusses the upcoming SCCE UK...more

FCPA Compliance and Ethics Report-Episode 3-Interview with Marie Patterson, Vice President of Marketing for Hiperos [Video]

In this episode of the FCPA Compliance and Ethics Report, I visit with Marie Patterson, VP of Marketing for Hiperos. We discuss the management of third parties by a commercial entity throughout the life cycle of the...more

Ahab Captures The White Whale: ‘In The Public Interest’ Defense To FCPA Enforcement

It is an axiom in the trial lawyer world that bad facts make bad law. The reason is if the facts are particularly egregious, most judges and juries will go out of their way to try and see that justice is served if not done....more

The Alchemist Of Comedy And Utility Industry Compliance

Harold Ramis died on Monday. For a generation of comedians and fans of comedy he was one of the driving lights of that genre. He was one of the screenwriters of Animal House and wrote the screenplays for both of the...more

Commitment To Compliance: The Compliance Committee

Sunday was the 69th anniversary the most iconic photo of World War II, at least from the American perspective. Of course it was the raising of the American flag at Mt. Suribachi on Iwo Jima. To say that one photo cannot...more

The FCPA Compliance and Ethics Report-Episode 36, Visit with the FCPA Professor-Part 1 [Video]

In this Episode 36 of the FCPA Compliance and Ethics Report, I begin a two-part interview with the FCPA Professor. In this episode, we talk about what is on the mind of the Professor and he discusses some of his blog posts...more

Tales From The Crypt - Rule No. 1 ‘Nothing Is As It Seems’

Tales From the Crypt: Tough Choices for Tough Cookies - Tough Cookie 1 has spent the more than half of her 20+ legal career working in the Integrity and Compliance field, and has been the architect of award-winning and...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

FCPA Compliance and Ethics Report-Episode 35-Transaction Monitoring [Video]

In this episode, I discuss the evolution of transaction monitoring in a best practices compliance program. ...more

The Simon-Sting Tour And New Information In Your Compliance Program

This past weekend I saw the first show in a multi-city tour by Sting and Paul Simon. I have never been a big Sting or Police fan but I am a huge Paul Simon fan, in all his musical incarnations. As it was their first show,...more

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