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Scrooge and Corporate Settlement Agreements

Although there seems to be a difference in the precise publication date between the online reference sites This Day in History and Wikipedia, today we celebrate the Charles Dickens’ work A Christmas Carol, which both sites...more

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou...more

The FCPA Compliance and Ethics Report-Episode 114-Doing Compliance, The Book [Video]

In this episode, I discuss my recently released book, Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program...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

Sherlock Holmes and Innovation in the Compliance Function, Part I – A Study In Scarlet

Today begins a week of double themed blog-posts. First I am back with an homage to Sherlock Holmes, for it was in the magazine Beeton’s Christmas Annual that the characters Sherlock Holmes and Watson were introduced to the...more

The Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices...more

FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA [Video]

In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more

Atlanta Burns – the Bio-Rad FCPA Enforcement Action – Part III

On this date in 1864, the Union Army phase of the destruction of Atlanta began. While most Southerners credit Union General William T. Sherman with the burning of Atlanta, it was, in reality, Confederate General John Bell...more

fcpa Compliance and Ethics Report-Episode 106-interview with Gini Deitrich [Video]

In this episode I visit with Gini Deitrich, well-known communications and PR expert and author of the recent book Spin Sucks. Gini discusses some of her lessons from this book for the compliance practitioner. ...more

Bribery and the Classroom (not in the Classroom)

“Mr. Bistrong, in the complaint it was alleged that you were a conspirator in bribing foreign officials in multiple countries, such as Nigeria, the UK, and the Netherlands, as well as bribing UN officials. Were there...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

Don’t Collapse in the Wind – Knowledge is Power

On November 7, 1940, high winds buffeted the Tacoma Narrows Bridge leading to its collapse. The first failure came at about 11 a.m., when concrete dropped from the road surface. Just minutes later, a 600-foot section of the...more

FCPA Compliance and Ethics Report-Episode 104-interview with Russ Berland [Video]

In this episode, I visit with Russ Berland, who was outside counsel heading up the FCPA investigation for Layne Christensen. I discuss with Russ the fabulous he was able to achieve, a Declination to Prosecute from the DOJ and...more

Supplier Risk Management – Interconnected Processes

I recently read a book review in the Times Literary Supplement (TLS) by Archie Brown, entitled “One into fifteen”, where he reviewed the book “The Last Empire” by author Serhii Plokhy. Plokhy’s book is about the dissolution...more

Tribute to Jack Bruce – Finding Talent to Support Your Compliance Function

Jack Bruce died last week. He was simply one of the greatest rock and roll bassist of all-time, as in ever. He helped form Rock’s first super group Cream when he joined with guitarist Eric Clapton and drummer Ginger Baker to...more

FCPA Compliance and Ethics Report-Episode 102-interview with Bruce Carton [Video]

In this interview I visit with Bruce Carton, founder and editor of Securities Docket. We discuss the recently concluded 2014 Securities Enforcement Forum; its panels, discussions and vibe. ...more

Compliance at the front lines in Ukraine-interview with Timur Khasanov-Batirov

Ed. Note- a couple of weeks ago, I had a guest post from Timur Khasanov-Batirov about some of the challenges in the doing of compliance in his native Ukraine. He certainly had an interesting and most welcome perspective. I...more

FCPA Compliance and Ethics Report-Episode 101-interview with Chris Bauer [Video]

In this episode 101 of the Compliance and Ethics Report, I visit with Chris Bauer. Chris is a well-known ethicist who speaks, writes, lectures and teaches about ethics in business. ...more

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

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