Do As I Say, Not as I Do: IMF and Ethics at the Top

In an article in Monday's New York Times (NYT) entitled " At I.M.F, a Strict Ethics Code Doesn't Apply to Top Officials ", Graham Bowley reported that there are two separate sets of ethics guidelines; one for the 2400 "rank-and-file staff and another for the 24 elite executive...

Implementing a Values-Based Approach to Your Compliance Program

In an article in the March issue of Inside Counsel entitled, " Interactive Ethics " author Brian Martin, Senior Vice President and General Counsel of KLA-Tencor Corp., discussed some of the lessons learned when his company transformed its compliance and ethics training from a rules- based...

FCPA Training: Some Practical Aspects of Resisting a Bribe

I recently was asked to prepare some Foreign Corrupt Practices Act (FCPA) training which used examples of requests for bribes to help prepare the company's employees if they are solicited to pay a bribe. To do so I relied on the expanded edition of Resisting Extortion and Solicitation in International...

Fostering Compliance Across Your Company

In the July-August issue of the Harvard Business Review , in an article entitled " Are You a Collaborative Leader ", authors Herminia Ibarra and Morten Hansen discuss how great Chief Executive Officers (CEOs) keep their teams connected. The authors' basic thesis is that the hyper-connected...

Branding Your Compliance Project

My "This Week in the FCPA" colleague Howard Sklar often talks about the internal corporate negotiations that a Compliance Department must engage in to obtain funding for compliance projects. Even with the economy on the upswing many corporations are still being extremely conservative on...

Will No One Rid Me of this Meddlesome Priest?

Tone at the Top has become a phrase inculcated in the compliance world. The reason it is so important to any compliance program is because it does actually matter. Any compliance program starts at the top and flows down throughout the company. The concept of appropriate tone at the top is in the...

Henry II Revisited: The Fair Process Doctrine as a Key Component of a Compliance Program

In a recent post entitled " Will No One Rid Me of this Meddlesome Priest? " I highlighted 'Tone at the Top' by discussing the words of Henry II leading to the subsequent murder of Thomas Becket. One of the things I learned on my recent vacation to England was that Henry II developed...

Don’t Fold ‘Em: Making the Case for Ethical Leadership

In an article published in the June issue of ACC Docket, entitled " Playing the Cards You're Dealt ", James Nortz raised the interesting issue of the lack of company leadership to "create an ethical vision, the moral courage to pursue that vision and the ability to effectively ...

Using the Octagon: Lozier’s Eight Steps to Further Your Compliance Program

In an article published in the July 29, 2011 issue of the Houston Business Journal entitled " Eight Steps to a More Effective Anticorruption Compliance Function " Chris Lozier , Principal at UHY Advisors in Houston and Manager of the FCPA - Foreign Corrupt Practices Act - Anti-Corruption...

Lean Knowledge Principles: Application to the Compliance Program

In the October 2011 issue of Harvard Business Review is an article, entitled " Lean Knowledge Work ", where authors Bradley Staats and David Upton explore the issue of whether the lean knowledge principles derived from the Toyota Production System can be applied to knowledge work. While...