Ethics The Foreign Corrupt Practices Act

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On the Oregon Trail: the BHP Enforcement Action and High-Risk Hospitality

The settlers who took off on this Great Emigration on the Oregon Trail did not have anything in the way of a road map. Fortunately for the modern day anti-corruption compliance practitioner, you do have road maps that can...more

Why Reputation Risk is Quickly Climbing the Ethics and Compliance Priority List, Part 3 | Beyond Compliance Training

So far in this series, we’ve discussed why companies are adopting a more public focus on ethics and compliance, how reputational risk can impact a company and its brand, and the first three elements of a five-part framework...more

FCPA Compliance and Ethics Report-Episode 159-Alison Taylor on the intersection of CSR and the FCPA [Video]

In this episode I visit with Alison Taylor of BSR about the organizational behavior issues around bribery and corruption and the intersection of Corporate Social Responsibility and the FCPA. ...more

I Was An Irrational Compliance Calculator

In what might be described as a “companion guide” to my Ethikos article Does Compliance Need More “Darkside,” I had a chance to read Scott Killingsworth’s work in the same edition, The Irrational Calculator: Sales at the...more

Senn Interview, Part III – Post Incident Remediation

I conclude my three-part series based upon my podcast interview of noted white-collar defense lawyer and Foreign Corrupt Practices Act (FCPA) practitioner Mara Senn, a partner at Arnold & Porter LLP. In Part I, I considered...more

How Smart, Connected Due Diligence Systems are Transforming Third Party Risk Management

The compliance field is in the early stages of a paradigm shift on managing due diligence—moving from a data drought to a data flood. Today’s compliance manager has to figure out how to proactively and continuously manage,...more

FCPA Compliance and Ethics Report-Episode 156-emergency podcast on Deflategate and the Wells Report [Video]

In the first emergency podcast Jay Rosen and I review (what we know) of the Wells Report into Deflategate. We consider the issues from a FCPA compliance practitioner perspective and what lessons may be learned from the...more

King Arthur Week – The Round Table and Compliance Professionals and Lawyers as Whistleblowers – Part III

Today we use King Arthur’s Round Table as the entry into our topic. The Round Table is the famous table around which he and his Knights congregated. Its shape implies that everyone who sits there has equal status. Wace, who...more

FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips [Video]

In this episode, I discuss some of the tools which a compliance practitioner or CCO can use to further compliance in an organization. ...more

Compliance: It Starts With A Village

A few weeks ago I had Mike Kenealy, COO of Insiders Integrity engage in a Q and A on “Just ‘Say No’ to Bribery but Prepare First. A Front Line Story,”. Last week, Mike shared with me a pro-bono project that he had sA few...more

FCPA Compliance and Ethics Report-Episode 153-Doing Compliance in an Economic Downturn [Video]

The energy industry is in turmoil from the drop in the price of oil from $100 down to around $50 per barrel. Many energy companies have laid off up to 30% of their workforce. What can you do from the compliance perspective...more

Interview with James Koukios

Ed. Note-today I continue my series of interviews with people prominent in the FCPA space. Today is James Koukios, formerly a Manager in the DOJ’s FCPA unit, who recently went into private practice at Morrison & Foerster....more

A Journey to the Dark Side of Business Ethics and Steps to Protect Your Organization

On May 11th, 2015 I will lead a session at the GRC Summit 2015 titled “A Journey to the Dark Side of Business Ethics and Steps to Protect Your Organization.” My journey comes not from the fields of audit, law, investigation...more

The Two Ps of Compliance: Promote and Protect

I often complain about compliance messaging. Compliance officers have to be careful to avoid becoming viewed as “nattering nabobs of negativism,” as former Vice President Spiro Agnew famously stated about the liberal media....more

Ingots of Gold & SEC FCPA Enforcement – Communication – Part IV

Today I want to use the Christie’s story Ingots of Gold as an introduction to some of the regular communications that the Securities and Exchange Commission (SEC) representatives frequently provide in public forums, regarding...more

FCPA Compliance and Ethics Report-Episode 140-Leona Lewis [Video]

In this episode I visit with Leona Lewis who recently left the compliance function at Best Buy to found her own compliance entity, ComplyEthic. Leona brings some very interesting insights from her days in consumer retailing...more

FCPA Compliance and Ethics Report-Episode 139-Amy Lilly, President of GHBER [Video]

In this episode I interview Amy Lilly, President of the Greater Houston Business and Ethics Roundtable (GHBER), the premier ethics and compliance organization in Houston. ...more

Reminders from the Goodyear FCPA Settlement

FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more

FCPA Compliance and Ethics Report-Episode 138, Tribute to Mr. Spock and Strict Liability for Internal Controls Under the FCPA [Video]

In this episode, I pay tribute to Leonard Nimoy and his immortal character Mr. Spock. I also discuss that the SEC may be moving towards a strict liability standard for internal controls under the FCPA....more

FCPA Compliance and Ethics Report-Episode 135, Kevin Brady on the process of sales for the compliance practitioner [Video]

In this episode I visit with noted sales process expert Kevin Brady who discussed sales as a process and how the compliance practitioner can use these concepts in communicating the message of compliance to an employee base. ...more

Future of Corporate Monitors

No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have a...more

FCPA Compliance and Ethics Report-Episode 125, The Oscars and Compliance, Part II with Jay Rosen [Video]

In this Part II of my five part series on the Oscars and Compliance, Jay Rosen and I take a look at the pre-Oscar awards and consider how a language assessment should related to your overall compliance risk assessment. ...more

2014 Corruption Perceptions Index Highlights Need for Greater International Cooperation

Following the release of Transparency International’s 2014 Corruption Perceptions Index (CPI), the international watchdog group urges greater international cooperation to stem corruption and abuses of power that undermine...more

From NH to Hollywood and Compliance Lessons from the Twins-interview with Jay Rosen

I grew up in Manchester, NH which the largest “city” in Southern New Hampshire with 100,000 residents.  We are effectively a bedroom community of Boston, which informs my fervent support of all things Boston: baked beans and...more

Just Say No, the Power of No and Compliance

What is the first thing that you think of about Former First Lady Nancy Reagan? Right up there for me is three things actually Just Say No, which was her campaign against not only drug abuse but also premarital sex in the...more

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