Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more
In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity. The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more
Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...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
I am nearing the end 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. ...more
As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more
In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more
Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more
Today at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski delivered the afternoon Keynote Address. He gave some significant comments around the corporate...more
Today, I conclude my short series on Shakespeare’s problem plays by considering Measure for Measure. In the age of #MeToo this play has taken on a renewed and frankly disturbing existence. ...more
This week, on the FCPA Compliance Report, I am running a five-part podcast series on the current state of investigative due diligence. ...more
What is the best way for a Chief Compliance Officer (CCO) to speak truth to power? How do you speak up to stop something that might cause a legal violation such as under the Foreign Corrupt Practices Act (FCPA)...more
This week I am running a special five-part sponsored podcast series with Vincent DiCianni, founder and President of Affiliated Monitors, Inc. (AMI) and Eric Feldman, Senior Vice President of AMI. ...more
What allows major ethics and compliance scandals to continue to hit multinational organizations? When it involves bribery and corruption, the likelihood of a lengthy, extensive and expensive Foreign Corrupt Practices Act...more
This week, I am running a five-past podcast series on the assessment of ethics and compliance in the mergers and acquisition (M&A) context. The podcast series was sponsored by Affiliated Monitors, Inc., (AMI)....more
This week I am running a five-part podcast series on assessing ethics and compliance in the mergers and acquisition (M&A) context on the FCPA Compliance Report. ...more
This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more
V.S. Naipaul died last week. He was a Trinidadian born grandson of Indian indentured servants sent to the island to work in the sugar plantations. From those humble beginnings, Naipaul rose to the heights of the literary...more
This week I have been exploring how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more
Keith Jackson died last week. He was universally recognized as the Voice of College Football and announced college football games for over 40 years. According to his obituary in the New York Times (NYT), Robert A. Iger, the...more
What exactly does “corporate culture” mean? Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more
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
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 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
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