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
We live in a topsy-turvy world. This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has...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
Today we honor the US Women’s Soccer team who won their fourth World Cup over the weekend by defeating The Netherlands. The US controlled the entire match, much as they had for the entire tournament. They were tested to be...more
I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more
How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more
The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antithetical to HR, the company...more
The global chaos unleashed by the WannaCry ransomware virus reinforces that cyberattacks are not just the problem of IT departments. Compliance must play an integral part of any organization’s cross-functional cybersecurity...more
Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more
In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives. She posed it with the following question, “Are there mechanisms to enforce compliance...more
In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states: Incentive System – How has the company incentivized compliance and ethical behavior? How has...more
Robert M. Pirsig died last week. For anyone who went to college in the mid-70s, he was required reading in a variety of classes and disciplines for his seminal work Zen and the Art of Motorcycle Maintenance. There were a...more
This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more
The FCPA Guidance states, “In addition to evaluating the design and implementation of a compliance program throughout an organization, enforcement of that program is fundamental to its effectiveness. A compliance program...more
I had to go to the dentist yesterday. I went for what I thought was filling repair but I had somehow forgotten that it was a wisdom tooth removal and a filling repair. I know you are thinking either (1) why does someone his...more
Today I want to talk about two different techniques that your HR function can use to help the compliance function by honoring two very different yet equally famous baseball players who died on Sunday. The first was Jim...more
The Horror! The Horror! Those are the seminal words of Mr. Kurtz, Manager of the Inner Station, in Joseph Conrad’s novel Heart of Darkness. Today we celebrate Conrad, Józef Teodor Konrad Korzeniowski, who was born on this...more
This week I am presenting a series on hiring in the compliance industry based on interviews I did with Maurice Gilbert, the Managing Partner at Conselium Partners LP. Today, I want look at the presentation of the job offer to...more
In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more
I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “Understanding the World’s Greatest Structures:...more
I use the Golden Gate Bridge as an entrée to my continued discussion on the series on steps that you can use in your compliance program if you find yourself, your company or your industry in an economic downturn. Whether you...more
Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more
In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more
The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my...more
In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program. ...more
Governments in every country are taking international trade compliance seriously. Unlike other company departments that heavily rely on automation to track supply chain compliance, those departments responsible for...more