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
I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law such as Sarbanes-Oxley (SOX). Cristina Revelo said she would...more
What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as: An internal control is an action or process of interlocking activities designed to...more
Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more
In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...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
In the latest episode of the Compliance Perspectives podcast we are joined by Daniel Kahn, the Acting Chief of the Fraud Section at the Department of Justice. We begin the conversation with a discussion of the latest...more
In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more
Ed. Note-We welcome back Troy McAlister with another guest post. Troy brings 20 years of experience at both public and private companies, in public accounting and in a variety of industries. Troy has experience in...more
With a tip of the hat to my friends Tim Erblich and Ryan Morgan, I know this one had to hurt. Bob Gibson died this weekend. He was one of the top pitchers of all-time and together with Sandy Koufax dominated hitters in the...more
In the age of Coronavirus, it could well be time to assess your internal controls beyond a gap analysis. Consider what COSO says about assessing compliance internal controls. In its Illustrative Guide, COSO laid out its views...more
What are the obligations of a Board member regarding the Foreign Corrupt Practices Act (FCPA)? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to...more
What is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...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
Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...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
The Department Of Justice (DOJ) and Securities and Exchange Commission (SEC) have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs....more
A key analysis is whether there are controls in place to enforce the policies and whether those controls are documented. To help to answer this query, there are four issues to evaluate...more
The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more
In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more