Testing Your Compliance Program
Regulatory vs. Business Compliance
Grupo Empresarial y Control … ¿a qué te cojo ratón?
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Enhancing Compliance: The Power of Independent Monitorships in Consumer Protection — Regulatory Oversight Podcast
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance into the Weeds: Of Fat Fingers, Internal Controls and Compliance
Vicky Hanks of Blake Morgan on Building an Effective Employee Brand - Passle's CMO Series Podcast
Better Investigative Interviewing
Hot Topics in International Trade
Episode 301 -- Steve Naughton on Compliance and Complaince Education at Loyola Law School Program
Episode 298 -- Electronics Communications Risks and Ephemeral Messaging
Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
JONES DAY TALKS®: The Evolution of Corporate Compliance Programs: Key Issues for Multinational Companies
Compliance & Disaster Preparedness
Compliance Series Part 3: Ensuring Compliance Programs are Effective
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
The 2024 ECCP demands data-backed evidence of a genuine, embedded compliance culture. The DOJ’s stance is clear: a company’s commitment to compliance is only credible if it’s supported by data that reflects employee...more
Is your business in compliance with every law, rule, and regulation that it should be? If you can’t confidently say yes, it’s time for a compliance risk assessment. And even if you could confidently say yes six months ago,...more
Achieve your ESG goals in 2023 - Environment, Social, and Governance (ESG) is a top priority for organizations of all types and sizes, and it the compliance team is a key factor in the ESG equation. Much like regulatory...more
Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...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
Recently, Assistant Attorney General, Kenneth A. Polite Jr. delivered remarks at Compliance Week detailing how the DOJ evaluates corporate compliance programs. The purpose of clearly stating these expectations in detail is...more
I recently had the opportunity to visit with Michele Edwards, Partner at StoneTurn, to consider some of the impacts on corporate compliance programs from the recently released 2020 Update to the Department of Justice’s (DOJ)...more
In June, the Department of Justice (DOJ) published an Update to their Evaluation of Corporate Compliance Programs (2020 Update) which set out to provide additional clarity on how enforcement officials will evaluate an...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 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
It's been ten years since the Federal Acquisition Regulation (FAR) was amended to require government contractors to have a business ethics and compliance program – that's right, it's a requirement in every government contract...more
On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more
IMPORTANT BOARD COMPOSITION DEVELOPMENT - The board’s nominating committee will benefit from an overview of The Conference Board’s important new survey on board composition, turnover and refreshment. According to the...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
It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors. There are common factual scenarios that recur in...more
In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...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
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 settlers who took off on this Great Emigration on the Oregon Trail did not have anything in the way of a road map. Fortunately for the modern day anti-corruption compliance practitioner, you do have road maps that can...more
No company wants a corporate monitor. If you ask any General Counsel, Chief Compliance Officer or Chief Executive Officer, they can list an infinite number of alternative punishments they would rather suffer than have a...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more