Corporate

Recent Posts

An Event That Changed the World and Fostering Compliance Leadership – Part I
Posted on 24 Jun 2014 by Thomas Fox

This coming Saturday, June 28th, is the 100 th anniversary of most probably the single most momentous event of the 20 th century; the assassination of Archduke Ferdinand and his wife Sophie in Sarajevo, then located in the Austro-Hungarian Empire. I view... Read More

What Message Is Being Sent to CCOs by SEC Commissioners?
Posted on 21 Jul 2015 by Thomas O. Gorman

The role of the chief compliance officer is the talk of the Securities and Exchange Commission these days – or at least some of its Commissioners. Those who are speaking for the record agree that the role of the CCO is important. Those who are speaking... Read More

Code of Conduct, Compliance Policies and Procedures-Part II
Posted on 25 Jul 2014 by Thomas Fox

I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures... Read More

Social Media Week Part V – Tools and Apps for the Compliance Practitioner
Posted on 11 Aug 2015 by Thomas Fox

To conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next... Read More

On Compliance Leadership: From Edward VIII to LeBron James
Posted on 11 Dec 2014 by Thomas Fox

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the American divorcée... Read More

Compliance at the Tipping Point, Part III – The VW Emissions-Testing Scandal
Posted on 14 Oct 2015 by Thomas Fox

I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other commentators have written... Read More

VW Emissions Testing Scandal – View From the Board
Posted on 29 Sep 2015 by Thomas Fox

The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “ Problems at VW Start at the Boardroom ”, James B. Stewart was unremitting... Read More

Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program
Posted on 15 Jul 2015 by Thomas Fox

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “ Understanding the World’s Greatest Structures: Science and Innovation... Read More

Code of Conduct, Compliance Policies and Procedures-Part II
Posted on 25 Jul 2014 by Doug Esten

I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures... Read More

Taking the Rolls Out for a Spin? Maybe You Should Avoid Brazil
Posted on 10 Mar 2015 by Thomas Fox

Just as the GlaxoSmithKline PLC (GSK) case in China heralded a new day in international anti-corruption enforcement, the Petrobras case may be equally important going forward. The scope and breadth of the investigation is truly becoming worldwide. Last... Read More

The Strategic Use of Compliance
Posted on 24 Nov 2014 by Thomas Fox

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices Act (FCPA) or UK Bribery... Read More

SCCE Guidance on Compliance Program Incentives
Posted on 2 Oct 2013 by Thomas Fox

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... Read More

Bunkie Hunt and the Marketing of Compliance
Posted on 28 Oct 2014 by Thomas Fox

Nelson Bunker ‘Bunkie’ Hunt died last week. In a state filled with oversized egos and personalities (i.e. ‘ Texas-Rich’ ), Bunkie was one of the true giants. He was a son from the first marriage of the famous Texas oilman-legend... Read More

Social Media Week Part IV – Telling a Story About Honey
Posted on 10 Aug 2015 by Thomas Fox

I continue my exploration of the use of social media in doing compliance by taking a look at a very innovative social media solution to a difficult compliance issue around, of all things, honey. This example shows how creative thinking by a lawyer, in... Read More

Outsourcing Compliance and the CCO
Posted on 24 Oct 2011 by Doug Cornelius

One of the requirements of registration as a registered investment adviser is the appointment of a Chief Compliance Officer and the establishment of a formal compliance program. The SEC stated that a firm need not hire a new person to be the CCO. However... Read More

  • Blog Post: The Day the Music Died

    Most people will recognize the name of Gibson Guitar, one of the most widely known makers of guitars in the United States. Unfortunately the company was recently raided by the US Fish and Wildlife Service for a failure in the compliance arena. However, it was not for a violation of the Foreign Corrupt...
  • Blog Post: Outsourcing Compliance and the CCO

    One of the requirements of registration as a registered investment adviser is the appointment of a Chief Compliance Officer and the establishment of a formal compliance program. The SEC stated that a firm need not hire a new person to be the CCO. However, there will be a substantial time commitment...
  • Blog Post: SCCE Guidance on Compliance Program Incentives

    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)...
  • Blog Post: An Event That Changed the World and Fostering Compliance Leadership – Part I

    This coming Saturday, June 28th, is the 100 th anniversary of most probably the single most momentous event of the 20 th century; the assassination of Archduke Ferdinand and his wife Sophie in Sarajevo, then located in the Austro-Hungarian Empire. I view it as the singular event of the prior century...
  • Blog Post: Code of Conduct, Compliance Policies and Procedures-Part II

    I am reviewing the importance of a Code of Conduct and anti-corruption compliance policies and procedures in your compliance program and how you should go about drafting or updating Code of Conduct and anti-corruption compliance policies and procedures. Earlier, I reviewed the underlying legal and statutory...
  • Blog Post: Continuous Improvement Of Your Compliance Program, Part II

    Yesterday, I began a two-part series on continuous monitoring of your anti-corruption compliance program. In Monday’s post, I looked at the regulatory framework for such a requirement. In today’s conclude with some thoughts on how to continually improve and update your Foreign Corrupt Practices...
  • Blog Post: Bunkie Hunt and the Marketing of Compliance

    Nelson Bunker ‘Bunkie’ Hunt died last week. In a state filled with oversized egos and personalities (i.e. ‘ Texas-Rich’ ), Bunkie was one of the true giants. He was a son from the first marriage of the famous Texas oilman-legend H. L. Hunt. Well over 6 feet tall, he also neared...
  • Blog Post: The Strategic Use of Compliance

    What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. My inquiry goes both further and deeper. Has...
  • Blog Post: On Compliance Leadership: From Edward VIII to LeBron James

    On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the American divorcée Wallis Warfield Simpson. On the evening of December...
  • Blog Post: Taking the Rolls Out for a Spin? Maybe You Should Avoid Brazil

    Just as the GlaxoSmithKline PLC (GSK) case in China heralded a new day in international anti-corruption enforcement, the Petrobras case may be equally important going forward. The scope and breadth of the investigation is truly becoming worldwide. Last fall, one of the first questions raised was why...
  • Blog Post: King Arthur Week – The Quest for the Holy Grail and Compliance Defense – Part V

    We conclude our Arthurian themed week with the Holy Grail, which has fired the imagination of artists for millennia. What was the Holy Grail? According to Professor Dorsey Armstrong in her Teaching Company lecture series, entitled “ King Arthur: History and Legend ”, the Holy Grail has taken...
  • Blog Post: Great Structures Week I: Vitruvius, the Brooklyn Bridge and Compliance

    I recently completed a course from The Teaching Company, entitled “ Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity ”, taught by Professor Stephen Ressler. It was a wonderful learning experience about some of the world’s greatest...
  • Blog Post: Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program

    I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “ Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity ”, taught by...
  • Blog Post: What Message Is Being Sent to CCOs by SEC Commissioners?

    The role of the chief compliance officer is the talk of the Securities and Exchange Commission these days – or at least some of its Commissioners. Those who are speaking for the record agree that the role of the CCO is important. Those who are speaking for the record agree that the CCO should not...
  • Blog Post: Social Media Week Part I – Using Social Media In Your Compliance Program

    Welcome to Part I of Social Media Week. I recently did a webinar, hosted by The Network, on the use of social media in your Foreign Corrupt Practices Act (FCPA) compliance program. The response was as great as almost any other webinar in which I have participated. Based upon the overwhelming feedback...
  • Blog Post: Social Media Week Part IV – Telling a Story About Honey

    I continue my exploration of the use of social media in doing compliance by taking a look at a very innovative social media solution to a difficult compliance issue around, of all things, honey. This example shows how creative thinking by a lawyer, in the field of import compliance, led to the development...
  • Blog Post: Social Media Week Part V – Tools and Apps for the Compliance Practitioner

    To conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next week.) You need to remember that your compliance customer...
  • Blog Post: VW Emissions Testing Scandal – View From the Board

    The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “ Problems at VW Start at the Boardroom ”, James B. Stewart was unremitting in his criticism of the VW Board, when near...
  • Blog Post: Compliance at the Tipping Point, Part III – The VW Emissions-Testing Scandal

    I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other commentators have written about the VW scandal from a variety of angles...