Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge
FCPA Compliance Report: From Compliance to Commercial Value: Removing Friction with AI
Daily Compliance News: April 28, 2025, The Santos Sobs Edition
FCPA Compliance Report: Ellen Hunt on Compliance ROI and on a Due Diligence and the US Sentencing Guidelines
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
FCPA Compliance Report: Kristy Grant-Hart on A 360° Review of the Future of Compliance
Episode 365 -- Four Sanctions Cases Everyone Should Know
FCPA Compliance Report: AI, Data Compliance, and Ownership - A Conversation with Andrew Hopkins
2 Gurus Talk Compliance: Episode 49 - The Depression Episode
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
Daily Compliance News: April 3, 2025, The Tribute to Ice Edition
Compliance into the Weeds: The Role of Compliance Going Forward
Daily Compliance News: March 27, 2025, The Eliminate the District Courts Edition
Great Women in Compliance: The Future of Enforcement with Jennifer Lee
FCPA Compliance Report: Navigating the Complexities of FTO Designations and Compliance in Mexico and Latin America
Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and the World with Tom Fox, Malcolm Nance, and Philip Rohlik
FCPA Compliance Report: Celebrating the 2025 World’s Most Ethical Companies: Highlights with Erica Salmon Byrne
10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Compliance into the Weeds: More Compliance Challenges in the Trump Era
Daily Compliance News: March 12, 2025, The Ruth Marcus Resigns Edition
In a letter dated January 31, 2025, President Trump informed FEC Chair Ellen Weintraub that she is "hereby removed as a Member of the Federal Election Commission, effective immediately.” Weintraub made the letter public in...more
On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more
The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively...more
In late 2012, we created the Manufacturing Law Blog with the goal of providing our manufacturing clients with a holistic approach to the unique issues they face in their global operations. Starting in 2016, we began a new...more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
The Justice Department and the Securities Exchange Commission are back in business. The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. While many commentators sought to read the...more
Late Monday, the Department of Justice (DOJ) without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. ...more
In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period. Not long ago, many in the...more
Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more
I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem....more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more
Today, I conclude my tribute to Bob Dylan-Nobel Laureate, by discussing my personal favorite Bob Dylan song, Tangled up in Blue. The time shifts and jumps in the song have always resonated with me. Indeed, it is one of the...more
What is the intersection of innovation in your compliance program and the requirements of an effective compliance program? I find the answer to be found in Hallmark 10 of the Ten Hallmarks of an Effective Compliance Program...more
I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more
This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I...more
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more
The compliance profession faces many challenges. Some are more important than others. When it comes to evaluating performance, or measuring compliance programs, the profession has a steep uphill climb....more
The Greatest died this past Friday. There is only one man in my lifetime who earned that sobriquet and it was Muhammad Ali. Ali was the greatest sportsman in my lifetime and in 1999, he was named by the editors of Sports...more
This is my final Travel Edition from Venice. If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to...more