Six Steps to Implementing Continuous Monitoring in Your Compliance Program

    Anti-corruption, anti-bribery, anti-money laundering programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of implementing effective controls...

    Bill James, the Baseball Abstract and the Use of Metrics in Compliance

    As of today, the Houston Astros (at 2-1) are above .500 in wins and losses for the first time since July 2009. So we celebrate that most important of baseball metrics, the wins and losses. One of the joys of baseball is the almost innumerable metrics...

    Opening Day is Here – Hope and Melancholy for the Astros and Avon

    It is finally here, Opening Day for the Houston Astros. Although Major League Baseball (MLB) opened its 2012 season last week in Japan, I will have to go with my hometown team's home opener as my official day for the new season. So will the Astros...

    OCEG on Third Party Anti-Corruption Due Diligence

    My grandfather was a comic book collector. He collected all kinds and types of comics, from super-heroes to the Archie series. One of the series that he collected that I still think about from time-to-time was Classics Illustrated. Classics Illustrated...

    Compliance Self-Assessment: The Good, The Bad and The Ugly

    Today we channel Sergio Leone and Clint Eastwood in the context of the compliance assessment, which has been something that has evolved into a key component of a minimum best practices Foreign Corrupt Practices Act (FCPA) compliance program over the...

    This Week in FCPA Episode 34

    Tom and I, both in Washington DC for the Dow Jones Global Compliance Symposium, decided to do a live show, so to speak. We recorded on YouTube (the video quality isn't great because I was using my laptop camera. Also, you might find the sound to...

    FCPA Enforcement: Why Corporations Support DPAs and NPAs

    At the recent Dow Jones Global Compliance Symposium, there was a debate royal between Mark Mendelsohn and the FCPA Professor, Mike Koehler, regarding enforcement of the Foreign Corrupt Practices Act (FCPA). One of the points the Professor raised was...

    Earl Scruggs: Banjo, Bluegrass and the Fight against Corruption and Bribery

    Last Thursday, Earl Scruggs died. He was one of the musician's most responsible for my development in learning about, and appreciating, different styles of music. For musicians, he basically invented and then popularized the 3 finger picking style...

    Is a Major Bribery Prosecution Coming in Canada Under the CFPOA?

    "What did the President know and when did he know it?" That is the iconic question from the Watergate Hearings asked by Senator Howard Baker of various witnesses. In the case of the Canadian engineering company SNC-Lavalin Group Inc. (SNC...

    OECD Report on the SFO and the Bribery Act

    The OECD Working Group On Bribery highlighted the efforts the UK in the anti-corruption area in a most recent report (here). That Report also contains a number of recommendations for future improvements. The Working Group concluded that the SFO and...

    To Give or Not To Give and If So How, Under the FCPA

    To give or not to give? That is certainly a question but it may also include the question of the value of the gift. Under the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act gifts and entertainment continue to bedevil compliance practitioners...

    The FCPA Enforcement Process: Negotiating the Penalty

    I recently explored the issue of 'extraordinary cooperation' in the context of a Foreign Corrupt Practices Act (FCPA) enforcement proceeding and some of the concrete steps that a company could take to reduce its overall penalty assessed by...

    The Biomet SEC Complaint: Lessons for Internal Audit

    On March 26, 2012, both the Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) announced the resolution of enforcement actions against Biomet Inc. a US entity, which manufactures and sells global medical devices around the...

    What is ‘Extraordinary Cooperation’ in an FCPA Enforcement Action?

    In the recent BizJet Deferred Prosecution Agreement (DPA), which detailed a litany of corrupt payments made and approved at the highest level of the company to obtain and retain business in Mexico and Panama, the company received a monetary fine of...

    Biomet: The Latest FCPA Settlement in the Medical Device Industry

    One of the hallmarks of the New Era of FCPA enforcement is the increasing use of industry wide sweeps and investigations. The DOJ and the SEC have been conducting such an inquiry into the medical device industry. The actions against Johnson & Johnson...

    To Boldly Go…Where the Board Needs to Go

    Belatedly, we boldly go where no Canadian actor has ever gone before, to celebrate yesterday's birthday of William Shatner, Captain Kirk of the original Starship Enterprise. I thought about Captain Kirk and his leadership of the Enterprise in the...

    This Week in FCPA Episode 33

    Watch other episodes of This Week in FCPA For more information about LexisNexis products and solutions connect with us through our corporate site .

    Three Keys to the Role of a Chief Compliance Officer

    There is an ongoing debate in the compliance world about whether a company can or should combine or separate the role of the Chief Compliance Officer (CCO) from that of the General Counsel (GC). However, before a company can answer this question, it...

    OCEG Illustrated Series: Managing Corruption Risks

    How do you move off dead center? That was a question posed by my colleague Mary Jones in a recent guest blog post. She gave several concrete steps in answer to her own question. This question was further explored in the January issue of the Compliance...

    Mendelsohn and Denniston: A Compliance Dialogue

    Last week I attended the 2012 Global Ethics Summit hosted by Ethisphere. The first event was a conversation between Mark Mendelsohn and Brackett Denniston, Senior Vice President and General Counsel of General Electric (GE). They both had some interesting...

    The BizJet DPA: Cooperation is the Key

    Last week, the Department of Justice (DOJ) announced the resolution of an enforcement action under the Foreign Corrupt Practices Act (FCPA) involving the Tulsa based company, BizJet. The company is in the business of providing aircraft maintenance...

    Are You a Supervisor?

    As a compliance officer, how far do you need to go in dealing with a problem employee? The Urban case was trying to address this question, but got twisted up in procedural machinations. In dropping the case, the two SEC commissioners didn't explain...

    Ethics Matters

    The word 'ethics' is in the title of this blog. While I rarely write solely on the subject of ethics two recent events caused me to do so today. The first was an article last week by Matt Ellis, writing in his FCPAméricas Blog, who posted...

    The Story of Ajax: Fairness in Rewarding Employee Behaviors

    How does your company deal with the question of fairness in its compliance program? I thought about that question while reading an article in the New York Times (NYT), entitled " That Eternal Question of Fairness ", by Nancy Koehn. In her...