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
Episode 305 -- Deep Dive into SAP FCPA Settlement
In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more
In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...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 on the final countdown to Number 500. Next week, 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
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
What is in your digital exhaust? Is this something you have considered for your best practices compliance program? While you may not currently, hopefully by the end of this blog post you will see the wisdom in doing so....more
In a number of enforcement contexts, I am always struck by a common theme – crooks are able to obtain access to corporate money for improper purposes. You never hear about a crook who uses his own money to pay bribes or...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
John McCain died over the weekend. I cannot think of a much better example of someone who continually sacrificed himself for his country than McCain. ...more
Sometimes the equipment you are playing with changes, particularly when that equipment is controlled by someone other than yourself. In the compliance world, this means having a compliance program which is both nimble and...more