FCPA Compliance Report

What are some of the key court cases and enforcement actions around facilitation payments? Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay Rosen and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, in this special holiday edition. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to the Part V and our final entry of this five-part podcast series Jay Rosen and I produced in honor of the latest Star Wars movie The Last Jedi. Each day over this week, Jay and I reviewed a In this final entry, we consider Rogue One and the myth of the rogue employee. Learn more about your ad choices. Visit megaphone.fm/adchoices

The FCPA contains an explicit exception to the bribery prohibition for any “facilitation or expediting payment to a foreign official, political party, or party official for the purpose of which is to expedite or to secure the performance of a routine governmental action by a foreign official, political party, or party official”. “Routine government action” does not include any decision by a public...

In Part I 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.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In May 2014, FASB issued Accounting Standards Update, Revenue from Contracts with Customers for public business entities, certain not-for-profit entities, and certain employee benefit plans. In addition to changing things dramatically in the accounting and financial realms, this new revenue recognition standard which may significantly impact the compliance profession, programs and practitioners go...

How can you work to operationalize the Code of Conduct as articulated in the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs? The Evaluation focuses not on whether a company has a paper compliance program but whether a company is actually doing compliance. A company does compliance by moving it into the functional business units as a part of an overall business process. Tha...

In this episode, I visit with Don Fischer, a San Francisco and Washington, based lawyers who is one of the country’s leading practices dedicated to assisting corporations, universities and research institutions with the development of comprehensive Export Control compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices

What about the training on your finalized Code of Conduct? Learn more about your ad choices. Visit megaphone.fm/adchoices

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week ending December 8, 2017. Learn more about your ad choices. Visit megaphone.fm/adchoices

Next is the design of your Code of Conduct. Through attention to detail in the design process, you should be able to come out at the end with a Code of Conduct which will help you to more fully operationalize your compliance program.  Learn more about your ad choices. Visit megaphone.fm/adchoices

Next, the evolution of the structure and format of a best practices Code of Conduct. Initially, my experience with Codes of Conduct was that they were written by lawyers, largely for lawyers. This included ‘thou shalts’ and ‘thou shalt nots’ liberally sprinkled throughout a lengthy written document. The compliance community then evolved Code 2.0, where the writing was less turgid, and then somewhe...

In this episode Richard Lummis and I explore the leadership lessons from the Battle of Hue in Vietnam in 1968. We consider the failures of the American high command, the role of leaders on the ground and the NVA and Viet Cong perspectives.  Learn more about your ad choices. Visit megaphone.fm/adchoices

The Code of Conduct forms the basis of your ethical commitments. Learn more about your ad choices. Visit megaphone.fm/adchoices

The cornerstone of a best practices compliance program is its written standards. These include a Code of Conduct, policies and procedures. These requirements have long been memorialized in the US Federal Sentencing Guidelines. These requirements were incorporated into the 2012 FCPA Guidance. Learn more about your ad choices. Visit megaphone.fm/adchoices

In the episode, I consider two different issues around communication skills. The first is communicating across cultural boundaries.  The second is the technique of asking questions to boost leadership. One of the things most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. Learn more about your ad choices. Visit megaphone.fm/adchoices

What if you could multiple the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any compliance practitioner and compliance program. It is also something that is very possible by considering a 360-degree view of communications in compliance using multipliers. Learn more about your ad choices. Visit megaphone.fm/adchoices

Welcome to Episode 5 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we focus on typical concepts (or probably myths) of ways a Compliance professional might become a more valuable member of the management team rather than becoming most hated person in the organization. We will do it in plain language and in the simple game form. Learn more a...

Many compliance professionals in the corporate world work long and hard to rise to the senior management level in their organizations. It takes subject matter expertise, hard work and sometime propitious good fortune to get to the C-Suite level in a large company. However, many of the skills which work to get you there do not always serve you in the context of a 360-degree view of communication at...

In this podcast, we consider the joint role of a GC-CCO and the potential corporate governance issues involved when the roles are held by one person. Does this create an irreconcilable conflict? What are the different functions of the General Counsel and the Chief Compliance Officer. Learn more about your ad choices. Visit megaphone.fm/adchoices

What does the release of the Paradise Papers and the corruption crackdown in Saudi Arabia mean for the compliance program of a US or UK company? In this episode I explore some of the compliance related issues. Learn more about your ad choices. Visit megaphone.fm/adchoices

The life of a Chief Compliance Officer (CCO) can be intense and the one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at United Health Care, has talked about the techniques that a CCO can use to influence decision making in a company to do business in ethically and in compliance. She has called these techniques of persuasion “Seven Steps of Influence” and advocates a CCO em...

It is difficult to imagine today a harder situation than the country faced when FDR came to power in 1933. The task must have seemed overwhelming. Starting a new compliance leadership position at a new company can seem equally daunting. You need to not only think through your steps going forward but also how to execute them for maximum performance in this early part of your corporate career. Learn...

The debate about whether the compliance function should be located in a company’s legal department or in a separate compliance function has largely concluded that it should be independent because of the difference in the two discipline’s mandates; many in a corporate compliance function came from the General Counsel’s office or have legal training. The lack of law schools providing training in lea...

This Week in FCPA is the only weekly FCPA, compliance and ethics podcast show. Find out the top compliance stories in a short 30 minutes listen. Learn more about your ad choices. Visit megaphone.fm/adchoices