The second tipping point for compliance which has occurred over the last 30 days or so is the information which has leaked out that the Department of Justice (DOJ) is in the process of hiring an outside advisor to provide to the Foreign Corrupt Practices...
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...
Today I continue my exploration of the line of sight theory under which a Chief Compliance Officer (CCO) or compliance practitioner would have visibility across the lifecycle of a sales transaction so they could move from Detect to Prevent to Prescription...
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...
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.
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
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...
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...
Republished with permission of the FCPA Blog ( original post )
Alison Taylor described on the FCPA Blog how employees are “socialized into paying bribes and encouraged to believe that corruption is an inevitable and necessary response to the...
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...
Today we celebrate one of the most momentous anniversary’s in the history of the United States, for it was on this day in 1865, 150 years ago, that Confederate General Robert E. Lee surrendered his Army of Northern Virginia to Union Commanding General...
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...
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...
Today is the first of a two part interview with Robert “Bob” Appleton and is an edited version of the entire interview which will be available for download when part II is published next week.
Hi Bob, and thank you for sharing your experience...
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...