Ethics The Foreign Corrupt Practices Act

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Hallmark 3 – Oversight, Autonomy and Resources

I. Autonomy - The DOJ has made clear over the years the importance of this hallmark. In the FCPA Guidance it states, “In appraising a compliance program, DOJ and SEC also consider whether a company has assigned...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

Compliance is a Business

Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance...more

Train Your Board and C-Suite Now – The Under-Education of Corporate Leadership

The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your...more

Shareholders Will Get to Trial in Petrobras Corruption Scandal Action

Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Compliance Training – Part III: Effectiveness and Evaluation

This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I...more

Compliance Training – Part II: Risk Ranking and Design

Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and...more

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Father’s Day and Compliance?

I really never thought much about the connection until I read an article (on Father’s Day) in the June 2016 Issue of the Harvard Business Review, Managing the High Intensity Workplace, by Erin Reid and Lakshmi Ramarajan. The...more

Defining “Effective” Ethics and Compliance Programs

The compliance profession faces many challenges. Some are more important than others. When it comes to evaluating performance, or measuring compliance programs, the profession has a steep uphill climb....more

The Damaging Myth of the Rogue Employee

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives...more

The “Economic Costs” of Compliance Mandates

I always enjoy economists and the rigor of economic analysis. It has a logic all its own. Economic theory reveals the power of incentives and disincentives. Many critics of economic theory fail to see how it applies to...more

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more

[Event] CLE for In-House Counsel - A 2016 Update on Current Issues Relating to Your Business - June 2nd, Chicago, Ill

Please join us for a complimentary CLE seminar on current issues affecting your business. Taught by leading practitioners at Locke Lord, the seminar offers three hours of CLE credit, including one hour of Professional...more

GHBER Tribute to Jay Martin

This Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the...more

A Lesson in Compliance: Part I

You’ve been quite candid with your followers and readers about your compliance violations and subsequent jail term. One of your blog posts addressed the stark reality you experienced when you first found yourself sitting in a...more

A Teaching Moment Inside VimpelCom’s Boardroom

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

2016 Trends #8: Getting Serious About Anti-Bribery & Corruption Efforts and Third-Party Risk Management

By now, most organizations understand the importance of identifying and addressing any exposure they have to violations of anti-corruption and bribery (ABC) laws. Much attention has been given to recent cases, and to...more

Greatest Live Album of All-time and Fostering a Culture of Compliance

On the 14th February 1970 The Who recorded what I consider to be the best, or at the very least my favorite, live album of all-time. They recorded their concert at the University of Leeds and the resulting album was named The...more

Spud Webb and Corporate Culture

On this day 30 years ago, history was made when Spud Webb won the 3rd NBA Slam Dunk contest. Webb joined future Hall-of-Famers Michael Jordan, who won the inaugural contest in 1984, and Dominic Wilkins, who won the second...more

The Person (Idea) of the Year – Corporate Ethics and Culture

Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the...more

The Dangers of Quick Fix Solutions – Certifications and Compliance Defenses

When the going gets tough, the tough do not necessarily get going. This is evident in the world of corporate governance, compliance, and defense against aggressive government enforcement. Corporate lobbying interests are...more

Star Wars Week, Part III – VI – Return of the Jedi-Moderating Training

Today we continue our celebration and exploration of the first trilogy of Star Wars movies with a look at Episode VI. Return of the Jedi. In this final movie from the original three, the good guys win in the end after...more

Celebrating John Jay and Leadership in Compliance

Today we celebrate leadership in general and ethical leadership specifically in the person of John Jay. He was not one of the well-known founding fathers; nevertheless he was a key participant in the founding of the American...more

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