Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more
I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more
As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more
In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more
Spikes in sales in high-risk countries do not translate into sustained growth and without an effective compliance program in place your company may actually lose money....more
Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more
Next week, in a five-part podcast series sponsored by Affiliated Monitors, Inc. (AMI), I visit with Eric Feldman, Senior Vice President of AMI to consider the Department of Justice (DOJ) Evaluation of Corporate Compliance...more
Today at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski delivered the afternoon Keynote Address. He gave some significant comments around the corporate...more
This year is the 15th anniversary of Affiliated Monitors, Inc. (AMI). Next week I am running a five-part podcast series on the history of AMI and the sweep of history in the rise of independent monitors as well as the...more
What is the best way for a Chief Compliance Officer (CCO) to speak truth to power? How do you speak up to stop something that might cause a legal violation such as under the Foreign Corrupt Practices Act (FCPA)...more
This week I am running a special five-part sponsored podcast series with Vincent DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. ...more
What allows major ethics and compliance scandals to continue to hit multinational organizations? When it involves bribery and corruption, the likelihood of a lengthy, extensive and expensive Foreign Corrupt Practices Act...more
I took a course in design thinking last year so I could familiarize myself with the technique. One key is the input from your customer base as a part of the design process. For any Chief Compliance Officer (CCO) or compliance...more
In light of the evolving (or evolved) DOJ and SEC approach to FCPA enforcement in the merger and acquisition context, global companies have to emphasize their post-acquisition process. ...more
Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. ...more
This week, I am running a five-past podcast series on the assessment of ethics and compliance in the mergers and acquisition (M&A) context. The podcast series was sponsored by Affiliated Monitors, Inc., (AMI)....more
This week I am running a five-part podcast series on assessing ethics and compliance in the mergers and acquisition (M&A) context on the FCPA Compliance Report. ...more
This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more
This week I am posting a five-part series on FCPA compliance issues. While there have been many advances in the anti-corruption ethics and compliance field, there is still more work to do to advance effective strategies for...more
What are the considerations a company should employ when retaining a corporate monitor? I recently put that question to Vincent L. DiCianni, founder and President of Affiliated Monitors, Inc. (AMI), and Eric R. Feldman,...more
The ultimate success of a global ethics and compliance program often depends on the ability of local compliance officers to engage business operations in a specific country. ...more