News & Analysis as of

Training The Foreign Corrupt Practices Act Chief Compliance Officers

Code of Conduct Training – Now What?

by Michael Volkov on

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

CCOs Cannot Ignore C-Suite Risks

by Michael Volkov on

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

Make Sure You Address Compliance with Export Controls

by Michael Volkov on

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

What the Government Expects to Find in an Anti-Corruption Compliance Program

by Dentons on

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue

by Thomas Fox on

In this inaugural Mailbag Episode, I field questions from an earlier podcast on the training of third parties under the FCPA. ...more

FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA

by Thomas Fox on

In this episode I discuss the training of third parties under the FCPA. I review the DOJ/SEC FCPA Guidance on this issue; the risk ranking of third parties to help deliver your training; the types of training you can utilize...more

Making the Case for Compliance Training for Third Parties

by NAVEX Global on

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

by Thomas Fox on

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Five Quick and Easy Ways To Sabotage Your Compliance Training

by Thomas Fox on

Ed. Note-today we have a guest post from noted ethics and compliance expert, as well as steel guitar player, Chris Bauer. Okay, you know that you need to have effective compliance training but do you really know what...more

FCPA Compliance and Ethics Report-Episode 96-interview with Karen Schuder on the teaching of business ethics

by Thomas Fox on

In this episode I interview doctoral candidate Karen Schuder on her research into the teaching of business ethics. ...more

Creation of Yosemite and Putting Compliance at the Center of Strategy

by Thomas Fox on

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

by NAVEX Global on

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM

by Michael Volkov on

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Monitoring and Auditing Your Anti Corruption Compliance Program

by Michael Volkov on

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

by Michael Volkov on

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?

by Thomas Fox on

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

Improving Your Anti-Corruption Training Program

by Michael Volkov on

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

by Thomas Fox on

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

Monitoring Of Third-Party Agents And Distributors

by Michael Volkov on

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

How to Reach Your Audience in Compliance Training – The Use of Charisma

by Thomas Fox on

One often hears or reads about complaints that compliance training is dull, nay even boring. I mean, how many times can you expect someone to be lectured to on the riveting subject of the Foreign Corrupt Practices Act (FCPA)...more

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