Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program; and to create and foster a culture of compliance. While it seems...more
C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...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
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
We are now at a place where there is sufficient data, academic research and actual use cases from corporations and businesses that demonstrate good ethics and compliance programs are not simply good for business but when...more
I recently had the opportunity to visit with Stephen Martin, 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
I want to lay out some of the basics every Chief Compliance Officer compliance professional and compliance practitioner will need to begin with in dealing with this crisis. ...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
As most compliance practitioners know, the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, 2019 Guidance, concentrated focus on culture in a way the DOJ has not done previously. This concentrated...more
Corporate cultures do not operate in a silo or free from external influences. Yet again, another profound grasp of the obvious. Employees, managers and senior leadership all bring their own experiences, perspectives,...more
In this episode I visit with Parth Chanda, CEO of Lextegrity, a leading technology platform that combines the up-front due diligence approval of planned third-party spend with the analysis of actual spend — focused on fraud,...more
The full agenda for ACI's 36th International Conference on the Foreign Corrupt Practices Act this December is now available. See why this event stands apart as the annual gathering for the worldwide anti-corruption...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
One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more
What are the largest risks to a corporation? How have those risks continued to morph and change? What are some of the top enforcement priorities of agencies and regulators? Finally, what is the compliance response to both...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...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.[i] In issuing the new document...more
Q&A with Tom Fox on the role of innovation in compliance programs, coming on the heels of publication of his new book, "The Compliance Handbook."...more
Q&A with Tom Fox on the role of boards in a best practices compliance programs, coming on the heels of publication of his book, The Compliance Handbook....more
This week, I am running a special podcast series on assessing ethics and compliance in the series mergers and acquisition (M&A) context....more
Interestingly, the Department of Justice (DOJ) has been talking about the effectiveness of your compliance program since at least 2015. This was shown by the release in 2017 of its Evaluation of Corporate Compliance Programs...more
Corporations experience numerous tests of character. Perhaps one of the most important is how the company responds when facing potential misconduct. ...more