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
We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....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
We are on the final countdown, moving closer to Number 500. On Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...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
A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...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
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
Based upon the language of the Foreign Corrupt Practices Act (FCPA), 2012 FCPA Guidance, FCPA enforcement actions and relevant Opinion Releases, and allowing for inflation over the past 40 years, it would appear reasonable...more
One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the financial transactions of the...more
This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more
Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more
Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more
Compliance is a business. That statement should not come as a shock or even a surprise to anyone who has worked in the corporate world. Every part of a business should work towards doing business. Yet many compliance...more
Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...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
Quite simply, any compliance program starts at the top and flows down throughout the company. Before you arrive at tone in the middle and bottom, it must start with a commitment at the top. All regulatory schemes for...more
In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more