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The Need to Recognize Cultural Differences When Creating a Compliance Program

In an article in the June issue of the Harvard Business Review (HBR), entitled " Why 'I'm Sorry' Doesn't Always Translate ", authors William W. Maddux, Peter H. Kim, Tetsushi Okumura and Jeanne M. Brett wrote about the lack of understanding between Americans and Japanese over...

How to Influence FPCA Compliance as a Minority JV Partner

How does a company work towards achieving compliance with the Foreign Corrupt Practices Act (FCPA) in a Joint Venture (JV) or other business relationship where it holds less that 50% of the control? That question is often faced by US companies when they enter into a JV in many countries which require...

Integrating Your Compliance Risk: Where the Rubber Meets the Road

In listening to companies discuss compliance in the areas of anti-corruption under the Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML) or export control, one of the things that has consistently struck me is how siloed each of these groups invariably is within their company. Not only...

Napoleon’s Invasion of Russia and Risk Management

Today, June 12 is the traditional date given for Napoleon's invasion of Russia. I cannot think of a better anniversary to use to introduce the discussion of risk management. Do you think he made a risk assessment so that he could manage his risks? If he did, what were his risks and how would he go...

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...

10 Questions to Better Management Practices in a FCPA Program

One of the things that I sorely lacked when I worked in-house was any guidance on management practices towards the implementation of either legal or compliance initiatives. Most legal and compliance departments do not train their attorneys or compliance practitioners on management practices for compliance...