This past weekend I saw the remaining members of The Who
perform in their Quadrophenia Tour. While I had seen Roger Daltry perform the
rock opera Tommy, I had never seen Pete Townsend in concert. To say I was blown
away would be putting it mildly, especially as Quadrophenia does not even make
Doing something 'by the book' means more than following a
process. It means following that process during high stress times. One of the
things that I think gets missed when discussing compliance programs is the need
for rigor in the process. By this not only do I mean that your process needs...
Last week I attended the Society for Corporate Compliance
and Ethics (SCCE) Energy and Utilities Conference here in Houston. As usual,
SCCE put on a great event, the speakers and topics were all first-rate. As you
might expect at such an event, the informal conversations with other compliance
I recently read " War
Room: The Legacy of Bill Belichick and the Art of Building the Perfect Team "
by Michael Holley which is about Bill Belichick, the rise of the New England
Patriots and the sophisticated player evaluation system that Belichick and
others installed in New England. The...
Ben Affleck has certainly had his share of ups and downs
in his professional career. He shared an Oscar for Best Original Screenplay for
Good Will Hunting with his fellow Bostonian buddy Matt Damon at age 25.
Thereafter things were not always at that same height for him professionally.
He had a...
"You do not want to be spread too thin". When I heard
that phrase a light bulb went off inside my head. It was uttered to me by Jan
Farley, the Chief Compliance Officer (CCO) of Dresser-Rand. I asked Jan what he
meant by the phrase and he explained that you cannot stretch your compliance...
What exactly is doing business in an ethical manner? I
believe that the answer is different for each company. Ethical behavior can
translate into doing business in a manner that does not jeopardize the safety
of others and how you treat co-workers and subordinates. One of the things that
What is risk? Under the Foreign Corrupt Practices Act
(FCPA) and UK Bribery Act risk is generally doing business in a non-compliant
manner under these laws, where such action can increase the possibility of
engaging in or facilitating a corrupt payment or bribe. However, risk can
involve other areas...
Today in history should be known as "End of Military
Leaders Day" as not only is this the 199 th anniversary of Napoleon's
exile to Elba (although he did make somewhat of a comeback) it is also the 62 nd
anniversary of Truman's sacking of Douglas MacArthur (although MacArthur did...
How can you create or revise your compliance program? One
of the first steps you should take is to devise an action plan. A recent
article in the March edition of the Compliance Week magazine, entitled " Putting
Together an Action Plan for Compliance ", Joel Katz, the Chief Ethics and
The second day of Hanson Wade Oil and Gas Supply Chain
Compliance conference in Houston packed as much solid information into it as
did the first day. One of the sessions dealt with utilizing other corporate
functions to assist a compliance department in implementing or enhancing a
Billie Sol Estes died yesterday and when it comes to scam
artists from the great state of Texas, before there was Allen Stanford and his
magical Certificates of Deposits located in his private bank in Antigua, there
was Billie Sol Estes. Before Sir Allen came along, Billie Sol had a 50 year run
Sometimes a story will help you understand just what you
did not understand. Did you know that the Federal Bureau of Investigation (FBI)
launched a formal investigation in 1964 into the supposedly pornographic lyrics
of the song " Louie, Louie ." That FBI investigation concluded that the...
One does not have to look very far in the business world
to come across the phrase "Know Your Customer." A company certainly needs to
know if an entity that it may sell products or provide services to will pay for
those items. Running a Dun & Bradstreet credit check is routinely performed...
Can you synthesize and reconcile the world's leading
laws, regulations and commentaries on the best practices an anti-bribery
and anti-corruption compliance program? I recently saw one such approach by
Paul McNulty and Stephen Martin of the law firm, Baker and McKenzie. They have
What do national pastimes teach us about ethics and
compliance? I would argue plenty. While, for the most part, I have reserved myself
from writing about the Houston Astros fraud upon their fans this season in
claiming that (1) they are fielding a major league team and (2) are not trying
The GlaxoSmithKline PLC (GSK) matter continues to resonate across the compliance world. Ongoing news releases by the company and announcements from named and un-named sources on the underlying facts continue to generate press worldwide. But there are also several important lessons to be learned from...
What is due diligence? When did due diligence begin? What does it really mean to perform due diligence? Further, how do you tie the information that you obtain in the due diligence process into your ongoing compliance program? I thought about those questions in the context of two very different types...
It has often struck me that one of the things the compliance function must do is to internally market its role in a company. By this I do not mean the internal competition for funding that occurs annually, although that is certainly something which the compliance function must also go through. The internal...
Next week the Society of Corporate Compliance and Ethics (SCCE) will hold its annual conference in Washington DC. It is one of the top national conferences in compliance and ethics around. Together with K&L Gates LLP partner Amy Sommers I will be speaking on the recent GlaskoSmithKline PLC (GSK)...
The Morrill Act was a seminal moment in American education. This law, passed in 1862, provided that land-grant institutions of higher learning should be created “without excluding other scientific and classical studies and including military tactic, to teach such branches of learning as are related...
On Wednesday the Boston Red Sox won their first World Series at home since 1918. The Red Sox had finally bested the Curse of the Bambino back in 2004 when they defeated their 2013 opponent, the St. Louis Cardinals, but they won the Series in St. Louis. The celebration was palatable, even watching the...
This past weekend I caught Meatloaf on tour. To say he can still rock would be putting it mildly. His career has been long and varied, including stints in the cast of the Broadway production of Hair and, of course, as Eddie in the Rocky Horror Picture Show . But, as a college senior in 1978, it was the...
Tom Cruise: Did you order a Code Red ?
Jack Nicolson: You’re G__D__ right I ordered a Code Red .
The above lines were spoken in the movie version of “ A Few Good Men ”. If there was ever one scene which demonstrated that Tom Cruise can really act; for my money this was the scene...
I have long been interested in the intersection in the changes in attitude regarding safety in the workplace by corporations and the changing attitudes on doing business through bribery and corruption. As a trial lawyer defending corporations in catastrophic accident lawsuits, I saw a sea change in the...