Assessing Risk? ethiXbase is an Invaluable Tool

Most compliance practitioners have gotten the message that a risk assessment should inform the creation of, or enhancements to, your Foreign Corrupt Practices (FCPA) or Bribery Act anti-corruption compliance program. But just say that you are Compliance Officer and the Chief Compliance Officer (CCO)...

Running the Big Con in DC: Lessons for the FCPA Compliance Practitioner

Most people have seen the movie " The Sting ", starring Robert Redford and Paul Newman, which tells the story of an older con man, Newman, who shows a younger man, Redford, how to run 'the big con' on a gangster played by Robert Shaw. It was fiction. However, on the front page of the...

Ethical Leadership: Leading a Company Conversation on Compliance

Ethical leadership is absolutely mandatory to have a successful compliance program, whether it is based upon the US Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act. Senior management must not only be committed to doing business in compliance with these laws but they must communicate these...

What is Your Integrity Capital?

Compliance practitioners often hear that bribes must be paid in emerging markets to get anything done. Indeed a recent survey by CEB (formerly Corporate Executive Board) of more than 700,000 employees of multinationals around the world, discussed in a Harvard Business Review article, entitled "...

Send Lawyers, Guns and Money - Some Steps Law Firms Should Consider

One of my favorite lawyer songs is the Warren Zevon classic " Lawyers, Guns and Money ". I was reminded of that song when I sat on a panel on Wednesday with Dan Chapman and Mike Volkov, where we discussed recent enforcement actions and due diligence under the Foreign Corrupt Practices Act ...

Frankenstein, Lance Armstrong and FCPA/Bribery Act Compliance

We continue our series focusing on the classic Hollywood monsters from the Universal Pictures era by taking a look at Frankenstein. Unlike Dracula, where Bela Lugosi basically only played his character in one classic picture, the Englishman Boris Karloff played Frankenstein's monster in three pictures;...

Brother Can You Swop a Car? FCPA and Bribery Act Implications in the Barter Economy

While the economy has improved from the depths of the Bush Recession of 2008, things are not back where most businesses and governments would like them to be. One of the more interesting responses to the continuing economic doldrums that I have read about is the age old art of bartering. According to...