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Hammer Films’ Frankenstein and the Monster of Corruption in Brazil

Today we celebrate the initial two Hammer Films Frankenstein entries into the horror pantheon. These classic films, from the 1950s, were the The Curse of Frankenstein and The Revenge of Frankenstein. In both films Peter...more

Five Quick and Easy Ways To Sabotage Your Compliance Training

Ed. Note-today we have a guest post from noted ethics and compliance expert, as well as steel guitar player, Chris Bauer. Okay, you know that you need to have effective compliance training but do you really know what...more

DOJ’s Marshall Miller: You’re All FCPA Lawyers Now

Marshall Miller, the Justice Department’s principal Deputy Assistant Attorney General for the Criminal Division, has been heating up the compliance conference circuit in recent weeks. On September 17th, it was the Global...more

FCPA Compliance and Ethics Report-Episode 100-interview with Jeff Kaplan [Video]

In this 100th episode of the FCPA Compliance and Ethics Report, I visit with Jeff Kaplan, Founder of the Conflicts of Interest Blog and well known thought leader in compliance and ethics. ...more

Carlton Fisk, The Homer and Oversight of a Profitable Subsidiary

Today we celebrate one of the great moments in World Series history. At approximately at 12:34 AM on this date in 1975, Carlton Fisk came to bat at the bottom of the 12th, in Game 6 of the World Series between the Boston Red...more

Internal Controls Outside the US – Part IV

This post will conclude a short series I have presented on the issue of internal controls outside the US. I want to conclude by raising some ways in which a compliance professional can work to implement internal controls in a...more

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

Tommy Lewis, Dicky Maegle and the DOJ Call for Individual Prosecutions

Tommy Lewis died this week. For those of you uninitiated in college football, Lewis was an Alabama football player who jumped up off the Alabama bench to tackle Rice University halfback Dicky Maegle, who was scampering...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

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

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

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

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

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

FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program,... [Video]

In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more

FCPA Compliance and Ethics Report-Episode 92-Interview with Matt Kelly [Video]

The FCPA Compliance and Ethics Report is out. In this episode I visit with Matt Kelly, editor of Compliance Week about the upcoming Compliance Week Europe and Compliance Week West conferences, the COSO framework and internal...more

When Bribery Pays, People Bribe

As Alison Taylor (Senior Managing Director, Control Risks) stated in a recent Forbes Article, “Compliance and Risk: Clearing the Org Chart Hurdle, “the traditional preventative approach to risk management is proving...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

Use of Influence in the Compliance Function

One of the challenges for any Chief Compliance Officer (CCO) is how to influence the conduct and actions in a corporate environment, particularly as compliance is viewed as non-revenue generating and usually does not exist...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

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