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Monitoring and Auditing Your Anti Corruption Compliance Program  [Video]

Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in...more

FCPA Training: The Basics [Video]

This webinar provides a basic FCPA training program. A number of webinar attendees have requested that I conduct a basic FCPA webinar outlining how the FCPA statute applies to international business operations. The topics...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

How to Accurately Identify the Corrupt Intent Behind Bribery: Real Life Cases, Anti-Bribery Training

As I mentioned in my last blog, FCPA expert Tom Fox was recently asked in an interview by Corporate Compliance Insights to define the criteria for what constitutes a bribe under the FCPA. He outlined three key criteria: Is...more

Shirley Temple And Excellence In FCPA Training Video

Today we honor one of the most interesting personalities of the 20th century, Shirley Temple, who died yesterday. She was probably the greatest child actress of all-time, being the lead grossing star for five straight years...more

Survey Reveals Social Media Training Top Compliance Priority

In The Network’s online survey last month, we asked you which compliance initiatives you would consider a priority in 2014. While there are many compliance issues at hand – code of conduct refresh, social media compliance,...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

Why Anti-Bribery Training and Policies are Two Essentials to Fuel FCPA Compliance

FCPA compliance is a hot topic in the oil & gas industry. Unfortunately, hearing about violations in this sector isn’t all that unusual. In fact, according to The Network’s research (based on industry findings), over the past...more

Mandatory Training for Third Parties – Effective or Protective?

What is the risk? Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more

More Compliance Lessons From The Asiana/SFO Crash Investigation

I have long been interested in the intersection in the changes in attitude regarding safety in the workplace by corporations and the changing attitudes on doing business through bribery and corruption. As a trial lawyer...more

It’s The Great Pumpkin: Lessons In Process Validation And Oversight

Today is Halloween 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 gang, who...more

Making Your Training Program Effective

Returning to the theme of profound grasps of the obvious, compliance officers face numerous challenges where they need creativity and persistence. ...more

A Prescriptive Guide To Third Party Risk Management

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

Return To The Baker’s Dozen In A Best Practices Compliance Program – Total Part II

Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more

Kroll And Compliance Week Survey Anti-Bribery And Anti-Corruption

Not many people realize that the US has elected one president who served as a prisoner of war....more

Four Key Board Responsibilities for Monitoring Risk and Compliance

Introduction: High Pressure Regulatory Environment - Now more than ever, there is increased regulatory pressure on organizations – and their Boards of Directors – to create and maintain effective ethics and compliance...more

Improving Your Anti-Corruption Training Program

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more

Monitoring Of Third-Party Agents And Distributors

Try to imagine what DaVinci said to himself when he painted his last brush stroke on the Mona Lisa. Or consider what Tolstoy muttered to himself when he put down his pen after writing the last word of War and Peace....more

What To Do If Your Gut Says It’s Wrong: Lessons from Project Alpha

I often write about what can happen to companies who run afoul of the Foreign Corrupt Practices Act (FCPA). Usually enforcement actions focus on companies and not individuals. However, as is often pointed out by commentators...more

How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)

Thucydides or Herodotus; Herodotus or Thucydides. Which is your favorite? I admit to vacillating between the two. Thucydides wrote about the end of the Athenian dynasty from the Peloponnesian War and the debacle of the...more

Internal Advertising of Your FCPA Compliance Program

Spring training is upon us and I have always enjoyed this time of year because, as one might say, ‘hope springs eternal’ especially for baseball fans. But this year I have no hope for the Astros as they have cut their payroll...more

Socio-Economic and Cultural Risk Factors That Drive Corruption: A Focus on the ‘Supply Side’ of the Equation

This is the last installment of my three party series regarding Occupational Fraud. One can never lose focus on what I consider the key question as they enter or play within the international arena: What are the...more

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