FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
In corporate compliance, a guiding principle is the foundation for success or failure: Tone at the Top. This phrase encapsulates the role of senior executives—particularly the CEO—in setting the ethical standards, cultural...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more
We continue our celebration of the Houston Astros winning the 2022 World Series by considering defense in baseball and prevention and detection in a best practices compliance program. According to Stephanie Apstein, writing...more
Halloween is almost upon us and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts...more
I continue my Great Structures Week with focus on great structural engineering and its innovations in the medieval world – that being the Gothic Cathedral. I am drawing these posts from The Great Course offering, entitled...more
Michael Ortwein, Chief Compliance Officer of General Motors sits down for an exclusive video interview for ACI Insights with Rebecca Hughes Parker, Editor-in-Chris of Anti-Corruption Report. ...more
Today, we conclude our exploration of the Monaco Memo by considering what all this may mean for compliance professional going forward. Department of Justice (DOJ) officials have emphasized that the changes laid out in the...more
What skills will be needed for the mid-century Chief Compliance Officer (CCO) [yes just a few more years to 2030 and ‘mid-century’]. Moving into the CCO chair today is far beyond compliance expertise and legal knowledge. What...more
Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more
Corporate culture is finally being acknowledged as a key ingredient in a successful business, particularly one which operates ethically and in compliance. The Department of Justice (DOJ) formally recognized the need to assess...more
Over the weekend I saw Joel Coen’s The Tragedy of Macbeth on Apple TV. To say it blew me away would be putting it mildly. I have been reviewing the film this week and exploring my love of all things Shakespeare in this week’s...more
Perhaps the most prescient comment I heard during the height of the pandemic came from Jed Gardner, Group Director of Transformation at Linedata, which was that we have moved from disaster recovery to business continuity to...more
On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more
UK companies should be aware of the increasing focus on corporate culture by regulators on both sides of the Atlantic. In a recent speech that has garnered significant attention, US Deputy Attorney General Lisa Monaco...more
Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime last week (Monaco Speech). Her remarks were noted by many commentators, including on two Compliance...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
J.R. Richard died last week. Not familiar with that name? He is the greatest pitcher in Houston Astros history whose career was tragically ended by a stroke at age 30. How dominant was Richard? In his senior year in high...more
This week I have been exploring design thinking and its uses by the compliance professional. I began by review some of the steps you should take in that process. Next I a considered why design thinking can be such a powerful...more
Every Board of Directors need a true compliance expert sitting at the table. Almost every Board has a former CFO, former head of Internal Audit or persons with a similar background and often times these are also the Audit...more
Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more
ACI’s New York Conference on Foreign Corrupt Practices Act is returning in a virtual format on June 2 – 3, 2021. Once again, this anti-corruption event will gather the key stakeholders: senior government officials, industry...more
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
The losses on Terra Firma just keep piling up for our national treasures of great baseball players. Yesterday I wrote about one of my boyhood heroes, Joe Morgan. Today I want to honor the passing of Whitey Ford, who was a...more