The Foreign Corrupt Practices Act Chief Compliance Officers

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.
News & Analysis as of

Mickey Rooney And The 90 Cent Solution

We begin today with a word on the death of Mickey Rooney. Rooney’s career, spanning nearly 90 years was certainly was from a different era. He was short of stature and long in his number of marriages but as Bob Lefsetz noted...more

Anti-Corruption Digest - March 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Tales From The Crypt - Rule 6: Never Mix Business With Pleasure

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

3 Basic Steps to Improving the Effectiveness of Anti-Bribery Training

To say anti-bribery training is important is one huge understatement. It continues to be one of the key elements in any effective or any best practices compliance program. The US Sentencing Guidelines contains clear language:...more

Miners Triumph And Opinion Release 14-01

On this date in 1966, the Texas Western University (now UTEP) Miners won the NCAA Basketball Championship, beating the University of Kentucky Wildcats. Now the first round has not even started by March 19, but it is not the...more

The Ides Of March And Evaluation Of Compliance Risk

Tomorrow, March 15 is enshrined as one of the most famous days of all-time, the “Ides of March”. On this day in 44 BC, the “Dictator for Life” Julius Caesar was assassinated by a group of Roman nobleman who did not want...more

Machiavelli For Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince by Niccolò Machiavelli. Just how evil do many people view the treatise? Consider that...more

Remember The Alamo: Analogy For Compliance Officers?

Today is the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, when Texas declared its independence from Mexico...more

Overwhelmed? Planning And Execution In Compliance

What should you do when an event or series of events is so overwhelming that it staggers your ability to evaluate, plan and respond to it or them? I thought about that question when I read an article in the New York Times...more

FCPA Compliance and Ethics Report-Episode 3-Interview with Marie Patterson, Vice President of Marketing for Hiperos [Video]

In this episode of the FCPA Compliance and Ethics Report, I visit with Marie Patterson, VP of Marketing for Hiperos. We discuss the management of third parties by a commercial entity throughout the life cycle of the...more

Board Investigations And The Curse Of The Mummy’s Tomb – Part I

On this day in 1923, the tomb of King Tut was opened. It created a worldwide stir that has in many ways continued down into the 21st century. Clearly, the boy ruler influenced Steve Martin , (How’d you get so funky?, Funky...more

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

Compliance Defense – The Movie

In honor of The Movie Channel’s annual 28 days of Oscar, the upcoming Academy Awards and inspired by Jay Rosen’s prior career and the FCPA Professor’s hypothetical discussion between a Chief Compliance Officer (CCO) and his...more

Silver Blaze And Leadership-Find It, Fix It And Prevent It

Today, we continue our Sherlock Holmes week by drawing inspiration for lessons for the compliance practitioner from the story of Silver Blaze. I thought about the story of Silver Blaze when reading this week’s Corner...more

Five Golden Rules Of What Works – The Internal Marketing Of Compliance

I am attending the ACI Foreign Corrupt Practices Act (FCPA) Boot Camp in Houston. It is one of the best FCPA events held in Houston annually....more

Why You Must Educate Your Employees on the Meaning of “Anything of Value” (FCPA Training Series)

What constitutes a bribe under the FCPA? This question was posed to FCPA expert Tom Fox in an interview series by Corporate Compliance Insights. To echo his statements, there are three key criteria to consider: Is there...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

The Compliance Crystal Ball—Top 10 Compliance Trends For 2014

It is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014. 1. Executive Order 13627 Changes Government Contracting - Want a government contract...more

Benedict Arnold And How To Be A Game-Changer In Compliance

Today is the anniversary of the birth of one of the most notorious Americans of all-time: Benedict Arnold. His name is synonymous with the word traitor in the United States and in many ways more derogatory....more

Here We Come . . . Walking Down [Wall Street] – More “Aggressive” AML Enforcement On The Horizon

I always say that the government does not enforce the laws in secret – they tell business what they plan to do and then they carry it out. The announcement of an enforcement initiative is always followed by a series of press...more

A Lot Of Pain In KC And Leadership In Compliance

While sports fans can relive the triumphs and tragedies of their team’s ad naseum corporate leaders cannot not afford to do so. One key resource I have found, for not only the ideas of what a leader needs to do but the...more

Little Help From My Friends – Predictions For Ethics And Compliance In 2014

When it comes to predicting ethics and compliance trends and events for the new year, I admit I needed some help. So I reached out to two leading ethics and compliance specialists in the industry – Donna Boehme and Michael...more

Top 10 Compliance Trends For 2014

As 2013 wraps up, it is that time of year again when we dust off the compliance crystal ball and take a look at what might be in store for 2014: 1. Executive Order 13627 on Trafficking in Government Contracts —...more

Individual FCPA Enforcement Actions In 2013

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

My Favorite Blog Posts From 2013

One of the best things about the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and other anti-corruption practice areas is the top notch quality of commentators. While Mike Volkov regularly derides the FCPA paparazzi...more

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