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Ethics Compliance

This Week in FCPA-Episode 80, The Last Jedi Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

Name Is “Psychological Safety” but My Friends Call Me Culture

by NAVEX Global on

As a Millennial, I spend most of my money on avocados and read a lot about tech and entrepreneurship. The latter has led me to stumble across something called “psychological safety,” the former, to a lifetime of over paying...more

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

by Michael Volkov on

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

by Michael Volkov on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

This Week in FCPA-Episode 79, the Fire and Ice Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, in this week's fire and ice edition: 1. Former VW Engineer Oliver Schmidt sentenced to 7 years in jail...more

Practical Ethics – The New Way to Advance an Ethical Culture

by Michael Volkov on

I have always been struck by the “feel good” advocacy and advice from so-called ethics “experts.” Sure, it is great to talk about moral values, ethical principles, and other high-minded ideas that inspire an audience to...more

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

by Thomas Fox on

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

New FCPA Enforcement Policy Ends the Compliance Defense Debate

by Thomas Fox on

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

The Time Is Now for Legal Departments to Step Up in Ethics & Compliance

by NAVEX Global on

NAVEX Global’s 2017 Ethics & Compliance Benchmark for Legal Professionals reaffirms an increasingly common belief: Legal departments should take on greater leadership when it comes to ethics and compliance. Put another way,...more

Let's Have A Really Uncomfortable Conversation

Having recently returned from three weeks of corporate engagements and conferences across nine time zones, I should be exhausted, but instead I’m exhilarated. Originally published on the FCPA Blog, www.fcpablog.com. ...more

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more

Legal Risk Management Forum: panel highlights

by Ropes & Gray LLP on

Watch panels – in their entirety – from our Legal Risk Management Forum: http://bit.ly/2AirKK3. The Legal Risk Management Forum, a half-day forum hosted by the Financial Times and Ropes & Gray, brought together risk...more

2017 Ethics & Compliance Third-Party Risk Management Benchmark Report - Data and Insights to Put to Work in Your Program Today

by NAVEX Global on

In 2017, NAVEX Global partnered with an independent research firm to survey professionals from a wide range of industries about their approach to third-party risk management and due diligence. The findings in this report...more

[Webinar] Legal Insights Into Ethics & Compliance - December 5th, 10:00am PT

by NAVEX Global on

Join this free webinar to get unique insights and benchmarks for compliance programs from the eyes of legal professionals. You’ll hear how legal departments view compliance training, third-party risk management and policy and...more

Where is Compliance at Uber?

by Thomas Fox on

I am tempted to write something along the lines of “another month, another scandal at Uber” but I do not think that would really help any compliance professional or business executive learn from the latest FUBAR announced by...more

Compliance Training for Third Parties Needs a Game Plan

by NAVEX Global on

More than half (58 percent) of organizations surveyed in NAVEX Global’s 2017 Ethics & Compliance Third-Party Risk Management Benchmark Report ranked their third-party programs as mature or advanced. This is encouraging, but...more

Internal Controls for Gift Giving this Holiday Season

by NAVEX Global on

Thanksgiving and the start of the holiday season is upon us. I thought a review of internal controls around gifts was in order. Many companies effectively minimize the risk of inappropriate gifts through stringent...more

The Four Stages of the Compliance Investment Cycle

by NAVEX Global on

When you’ve been in compliance for a few years, you begin to notice a trend. Investment in compliance and ethics programs comes in waves, and it can be incredibly helpful to your sanity if you recognize that like many...more

This Week in FCPA-Episode 77, the Home for the Holidays Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner,...more

Putting Ethics Back Into Compliance (Part IV of IV)

by Michael Volkov on

My final posting on this week’s ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger...more

Using Movie Clips to Expand Your Compliance Classroom

by Thomas Fox on

Create unforgettable teachable moments - Instead of having lawyers drone on, giving forgettable instructions on ethics, culture and honesty; they will clearly enjoy a scene of a star like Leonardo DiCaprio bluffing his way...more

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

by Thomas Fox on

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Six Specific Areas to Embed and Promote Business Ethics (Part III of IV)

by Michael Volkov on

The challenge for corporations is to build practical approaches to business ethics and its specific corporate values. Business ethics as a field is all well and good but we need to start sharing specific and practical...more

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

Trust and Integrity – Bedrock of Corporate Sustainability (Part II of IV)

by Michael Volkov on

Here is another profound grasp of the obvious – all companies need to make a profit. However, as companies begin to focus on long-term performance rather than short-term quarterly objectives, innovative leaders believe...more

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