Compliance into the Weeds: Leaving on a (Qatari) Jet Plane
The Presumption of Innocence Podcast: Episode 61 - A Call to Service: From Public Duty to Spiritual Advocacy
Daily Compliance News: May 12, 2025, The Corruption in the Broad Daylight Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Daily Compliance News: May 8, 2025, The $1MM for a Pardon Edition
Daily Compliance News: May 5, 2025, The Washing Edition
Daily Compliance News: May 1, 2025, The 100 Days of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending April 26, 2025
Daily Compliance News: April 21, 2025, The Tribute to Pope Francis Edition
Daily Compliance News: April 15, 2025, The Redefining Corruption Edition
Daily Compliance News: April 14, 2025, The Cascade of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending April 12, 2025
Daily Compliance News: April 10, 2025, The Dark Money Corruption Edition
Daily Compliance News: April 9, 2025, The Corruption at the DOJ Edition
Daily Compliance News: April 8, 2025, The End of Monitors Edition
Daily Compliance News: April 7, 2025, The Whistleblowers Awarded Edition
Daily Compliance News: April 2, 2025, The All WSJ Edition
Daily Compliance News: March 26, 2025, The Missile Strike on Boeing Edition
Daily Compliance News: March 24, 2025, The ABC Task Force Edition
Episode 360 -- Natalie Druckman from Certa on AI-Enhanced Third-Party Risk Management
We continue our week-long look at the use of AI in compliance. Today, we consider third parties. Third-party relationships remain one of the most significant areas of risk for corporate compliance programs....more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more
The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management. The theoretical...more
In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more
Chief compliance officers are heroes. They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more
In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
Today, I conclude the topic of judgment for compliance professionals. I recently read a Harvard Business Review (HBR) article on the topic by Sir Andrew Likierman, entitled “The Elements of Good Judgment: How to Improve Your...more
I am in the midst of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. MLB issued...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more
From the HR and compliance perspective, there are four steps to undertaking a gap analysis: 1) understanding the compliance and HR environment in your organization; 2) taking a holistic approach to understanding the...more
As a Chief Compliance Officer (CCO) one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at UnitedHealthcare, has talked about the techniques that a CCO can use to influence decision making in a company...more
Last week there were two speeches by Department of Justice (DOJ) officials which directly impacted corporate compliance programs going forward. They were a speech by Principal Deputy Assistant Attorney General John P. Cronan...more
The drumbeat of those supporting ISO 37001 continues. However, I still find it to be misplaced as anything close to the international standard for anti-bribery/anti-corruption programs....more
One of the big differences in a corporate compliance function and in-house legal department is that compliance is there to prevent, find and fix problems while the legal department exists to protect a company from the...more
In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system....more
In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more
In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more
In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more