FCPA Compliance Report

What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the message of compliance going forward. Many of the applications that we use in our personal communication are free or available at very low cost. Learn more...

Today, I visit with Mark Rainsford and Jason Sugarman, principals with RS Legal Strategies which is a pioneering Queen’s Counsel led business crime, fraud and legal strategy boutique. Its world-class professionals include leading and junior counsel, a solicitor, a former member of the judiciary and special advisor to the Serious Fraud Office, two former investigators, analysts, researchers, tax fr...

A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and visible to your employees at all times. It is about creating a distinctive brand philosophy of compliance which is centered on your consumers. Learn more about your ad choices. Visit megaphone.fm/adchoices

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance program. The starting point is the FCPA itself. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with QuantaVerse CEO/Founder David McLaughlin on the company’s new tool, the Chief Audit Checkup service, which leverages the QuantaVerse AI Financial Crime Platform to analyze enterprise data and more efficiently and effectively identify insider threats, bribery, corruption, money laundering, fraud, terrorism financing and third-party risks that traditional internal audit...

There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The 2012 FCPA Guidance made clear that “Whether a company has policies and procedures that outline responsibilities for compliance within the company, detail proper internal controls, auditing practices, and documentation p...

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 lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action by using it to claim we are an ethical company. Is such a legalistic code effective? Is a Code of Conduct more than simply, your company’s law? Wh...

In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Jonathan Marks joins us to discuss his new Board and Fraud blog.  Learn more about your ad choices. Visit megaphone.fm/adchoices

What is the role of a company’s Board of Director as laid out in the Evaluation of Corporate Compliance Programs for more fully operationalizing a best practices compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

The Evaluation of Corporate Compliance Programs makes clear, a company must have more than simply at good ‘Tone-at-the-Top’; it must move down through the organization from senior management down to middle management and into its lower ranks. This means that one of the task is to get middle management to respect the stated ethics and values of a company, because if they do so, this will be communi...

In this episode, Richard Lummis and I consider the recent revelations which came to light that during the tenure of the former Chief Executive Officer, Jeff Immelt, he had an empty plane fly behind his jet on corporate trips. There were several points a Board of Directors can learn from these revelations going forward.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, Richard Lummis and I consider the recent revelations which came to light that during the tenure of the former Chief Executive Officer, Jeff Immelt, he had an empty plane fly behind his jet on corporate trips. There were several points a Board of Directors can learn from these revelations going forward.  Learn more about your ad choices. Visit megaphone.fm/adchoices

This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as it focuses on the conduct of senior management. The Justice Department wants to see a company’s senior leadership actually doing compliance. The DOJ asks if company leadership has through their words and concrete actions brought the right message of doing business ethically and in compliance to a company. How does senior mana...

In this episode, Matt Kelly and I take a look at some of the more intriguing issues in compliance and ethics, FCPA and greater GRC issues in the new year of 2018. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with SCCE incoming President Gerry Zack about his new role with the organization. Learn more about your ad choices. Visit megaphone.fm/adchoices

Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an important, key step as it will allow you to have full visibility of your compliance risks through a longer life cycle. Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay and I take things in a different direction this week. We take the top five podcasts from 2017 and each of us, gives a highlight from that episode to highlight some of the key compliance issues from 2017, for our year end wrapup edition. Learn more about your ad choices. Visit megaphone.fm/adchoices

Over the next 31 days, I will be exploring the best way to more fully operationalize a compliance program using the DOJ resources. Join me as we engage in 31 days to a more effective compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

This entry provides a wrap up on written standards, with a discussion on policies on cybersecurity. Regarding policies on cybersecurity, it has become so critical for corporation that the CCO and many compliance practitioners are now required to deal this issue. Learn more about your ad choices. Visit megaphone.fm/adchoices

The next area for policies is extortion payments, which are completely exempted out of the FCPA. Extortion payments are made for any action which threatens or demands payment for life, liberty, or health. These should be exempted out from your facilitation payments and your compliance program through specific language. As a compliance professional, you need to make sure employees understand they n...

As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act. The Department of Justice Evaluation of Corporate Compliance Programs devotes an entire prong to third party management. Learn more about your ad choices. Visit megaphone.fm/adchoices

In Part II of a two-part series, the top compliance roundtable podcast is back with a review of the new Justice Department’s FCPA Corporate Enforcement Policy. This episode features Jay Rosen and Jonathan Armstrong. Learn more about your ad choices. Visit megaphone.fm/adchoices

From the information provided by the Justice Department in Opinion Releases and in enforcement actions, there are several different insights which may be drawn on what should go into your policy on facilitation payments. Learn more about your ad choices. Visit megaphone.fm/adchoices

In this episode, I visit with Keith Read, Advisor to Convercent and Angus Robertson, Senior Vice President for Convercent on some of the key trends they observed in the marketplace in 2017, from the vendor perspective. I found this an interesting perspective as both of these gents spend quite a bit of time listening to compliance practitioner on what their needs are for their organizations. Learn...

In this special 2017 year-end wrap up, host Richard Lummis and myself reflect back on the leadership lessons we explored over the past year. In this momentous year for leadership, both in business and the wider polis, we considered academics, numerous Presidents, movies, sports figures and some of the current corporate scandals which populated the year. Learn more about your ad choices. Visit mega...