Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
What the Board Should Be Asking About the Compliance Program
Episode 327 -- Another Look at the Importance of Corporate Culture
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Coming Perfect Storm
Overcoming Internal Barriers to Compliance Success
Episode 301 -- Steve Naughton on Compliance and Complaince Education at Loyola Law School Program
Episode 299 -- Bobby Butler on the Compliance Profession and the Future of Compliance
Compliance Auditing & Monitoring
Global or Local: The Constant Dilemma in Compliance
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
Episode 281 -- NAVEX 2023 State of Risk and Compliance Programs
Improving Your Face to Face Communications
Compliance Perspectives: Compliance Champions
Compliance Perspectives: Compliance & Corporate Governance in the Time of COVID-19
12 O'Clock High, a podcast on business leadership-Episode 116: Leadership Lessons from the Dutch Tulip Bubble of 1636-1637
Nota Bene Episode 51: The Four Fundamentals of a Corporate Governance Crisis with John Tishler
Across the Board-Episode 5, Visualization of Data for a Board
In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more
In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more
CEP Magazine - November 2022 - Before getting into compliance management, it is opportune to consider proactive and reactive management as a process. Proactive managers control their destinies by thinking ahead and...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
Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance...more
We are on the final countdown to Number 500. Next week, on Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...more
The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more
As most compliance practitioners know, the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, 2019 Guidance, concentrated focus on culture in a way the DOJ has not done previously. This concentrated...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
According to a recent Foreign Corrupt Practices Act (FCPA) Blog entry (11/28/18), over 40% of internal frauds are discovered by whistleblowers and statistics show that 74% of whistleblowers are terminated. ...more
What is in your digital exhaust? Is this something you have considered for your best practices compliance program? While you may not currently, hopefully by the end of this blog post you will see the wisdom in doing so....more
In a number of enforcement contexts, I am always struck by a common theme – crooks are able to obtain access to corporate money for improper purposes. You never hear about a crook who uses his own money to pay bribes or...more
Interestingly, the Department of Justice (DOJ) has been talking about the effectiveness of your compliance program since at least 2015. This was shown by the release in 2017 of its Evaluation of Corporate Compliance Programs...more
John McCain died over the weekend. I cannot think of a much better example of someone who continually sacrificed himself for his country than McCain. ...more
Sometimes the equipment you are playing with changes, particularly when that equipment is controlled by someone other than yourself. In the compliance world, this means having a compliance program which is both nimble and...more
In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more
Glen Campbell died yesterday. He was truly an American original. He grew up dirt poor, as a sharecropper’s son, near Delight (pronounced DEE-light), Arkansas and went onto to achieve worldwide fame. While many will remember...more
Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more
I have been exploring innovation in the compliance function this week. For my final piece I want to consider the innovation process itself. In an article in the MIT Sloan Management Review, entitled “Finding a Lower-Risk Path...more
This Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the...more
There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more
One of the ongoing battles for any Chief Compliance Officer (CCO) or compliance practitioner is that the business folks usually view compliance as the Land of No; most often populated by Dr. No him or herself. You will have...more
Over this week I have looked at some issues related to compensation and methods from other disciplines that a compliance practitioner might use to test and then improve a company’s third party management regime. Today, I want...more
I continue my exploration of the Marx Brothers this week by looking at their most successful commercial film made for Paramount, Horse Feathers. While Duck Soup is and always will be my favorite film due to its overall and...more
Giving away my old age, we all loved the 1960s Batman series starring Adam West. Thanks to the Batman show we were given a long list of words to underscore Batman and Robin’s slugfests with the weekly villain (e.g. Penguin,...more