Another FIFA Compliance Failure – Referees at the World Cup

Although the organization puts on arguably the greatest sporting event for professional athletes on the planet, the term ‘professionalism’ is probably not one you can associate with the Fédération Internationale de Football Association (FIFA). Unfortunately this lack of professionalism...

Code of Conduct, Compliance Policies and Procedures-Part I

This is part one of a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the documents as a foundation of your overall anti-corruption regime. In subsequent posts, I will review...

Code of Conduct, Compliance Policies and Procedures-Part II

I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures. Earlier, I reviewed the underlying legal and statutory...

Code of Conduct, Compliance Policies and Procedures-Part III

Today, I continue with Part III of my four-part series on the best practices surrounding your Code of Conduct and anti-corruption policies and procedures. In this post, I take a look at drafting policies and procedures. I conclude with some thoughts by well-known policy pundit Michael Rasmussen on management...

Code of Conduct, Compliance Policies and Procedures-Part IV

This is the fourth and final installment of my series on the the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures. On...

Theme from Shaft and Continuous Improvement of Your Compliance Program, Part I

The composer of what I believe to be the absolute coolest movie theme ever, Isaac Hayes, was born August 6, 1942. Hayes continually succeeded in many areas. In the 1960s it was with soul music on the great label Stax. In the 90s it was as the voice of Chef on the animated TV series South Park . But for...

Continuous Improvement Of Your Compliance Program, Part II

Yesterday, I began a two-part series on continuous monitoring of your anti-corruption compliance program. In Monday’s post, I looked at the regulatory framework for such a requirement. In today’s conclude with some thoughts on how to continually improve and update your Foreign Corrupt Practices...

Risk Assessments-the Cornerstone of Your Compliance Program, Part I

Yesterday, I blogged about the Desktop Risk Assessment . I received so many comments and views about the post, I was inspired to put together a longer post on the topic of risk assessments more generally. Of course I got carried away so today, I will begin a three-part series on risk assessments. In...

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

Ed. Note-Today, I continue my three-part posts on risk assessments. Today I take a look at some different ideas on how you might go about assessing your risks. One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different...

Risk Assessments-the Cornerstone of Your Compliance Program, Part III

Today, I conclude a three-part series on risk assessments in your Foreign Corrupt Practices Act (FCPA) or UK Bribery Act anti-corruption compliance program. I previously reviewed some of the risks that you need to assess and how you might go about assessing them. Today I want to consider some thoughts...

Creation of Yosemite and Putting Compliance at the Center of Strategy

On this day in 1890, an act of Congress created Yosemite National Park, home of such natural wonders as Half Dome and the giant sequoia trees. Environmental trailblazer John Muir (1838-1914) and his colleagues campaigned for the congressional action, which was signed into law by President Benjamin Harrison...

Hammer Films, “We Sell Hammers” and Other Famous Last Words

Today is the first of five Fridays in October so today I will begin my now annual October FrightFest blog posts. Over the past couple of years I have focused on the classic Universal horror movies from the 1930s and 40s. This year I am going to re-watch and blog about the classic Hammer Studio monster...

Internal Controls Outside the US – Part IV

This post will conclude a short series I have presented on the issue of internal controls outside the US. I want to conclude by raising some ways in which a compliance professional can work to implement internal controls in a multi-national organization. As with my entire series on internal controls...

Bunkie Hunt and the Marketing of Compliance

Nelson Bunker ‘Bunkie’ Hunt died last week. In a state filled with oversized egos and personalities (i.e. ‘ Texas-Rich’ ), Bunkie was one of the true giants. He was a son from the first marriage of the famous Texas oilman-legend H. L. Hunt. Well over 6 feet tall, he also neared...

Doing Compliance-The Book

I have consistently tried to bring a ‘Nuts and Bolts’ approach to my writing about compliance. Last year when describing some of my writing on the building blocks of a Foreign Corrupt Practices Act (FCPA) compliance program to my friend Mary Flood, she said “That’s great but what...

Giants Join Pantheon of Greats Through the Confluence of Culture and Strategy

Last week the San Francisco Giants won their third World Series championship in five years. This elevates them into the conversation of the Pantheon of elite teams over the past 50 years. Only the New York Yankees (1998-2000) and the Oakland Athletics (1972-1974) can top the Giants for Worlds Series...

Supplier Risk Management – Interconnected Processes

I recently read a book review in the Times Literary Supplement (TLS) by Archie Brown, entitled “ One into fifteen ”, where he reviewed the book “ The Last Empire ” by author Serhii Plokhy. Plokhy’s book is about the dissolution and final days of the Soviet Union. One of...

The Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. My inquiry goes both further and deeper. Has...

Sherlock Holmes and Innovation in the Compliance Function, Part I – A Study In Scarlet

Today begins a week of double themed blog-posts. First I am back with an homage to Sherlock Holmes, for it was in the magazine Beeton’s Christmas Annual that the characters Sherlock Holmes and Watson were introduced to the world in 1887, in the short story A Study in Scarlet . The second theme...

Sherlock Holmes and Innovation in the Compliance Function, Part II – The Sign of Four

Today we honor Conan Doyle’s second Sherlock Homes novel, The Sign of Four. The novel was published in 1890 but the story is set in 1888. The story entails a complex plot involving service in East India Company, India, the Indian Rebellion of 1857, a stolen treasure, and a secret pact among four...

Sherlock Holmes and Innovation in the Compliance Function, Part III – The Hound of the Baskervilles

Today we honor Conan Doyle’s third Sherlock Homes novel, The Hound of the Baskervilles. The novel, originally serialized in The Strand from 1901 to 1902, is generally recognized by Sherlockians as the premier Doyle work regarding his fictional detective. Interestingly, Bertram Fletcher Robinson...

Sherlock Holmes and Innovation in the Compliance Function – Part IV, The Valley of Fear

Today I conclude my dual-themed week of blog posts featuring Conan Doyle’s four Sherlock Holmes novels and innovation in the compliance function. As the compliance profession matures and we move into what I call the era of CCO 2.0. Today we celebrate Doyle’s final novel, The Valley of Fear...

Bobby Keys, the Rolling Stones and Establishing Trust

Bobby Keys died last week. What you probably did not know was that Keys was a Texan so we get to claim him. He was the saxophonist for the Rolling Stones and a number of other serious rockers. As Bruce Weber wrote in his New York Times (NYT) obituary, entitled “ Bobby Keys, Hard-Living Saxophonist...

On Compliance Leadership: From Edward VIII to LeBron James

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the American divorcée Wallis Warfield Simpson. On the evening of December...

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou Adler. These facts, the story of the song, its recording and release were related...