Corporate

Recent Posts

Compliance at the Tipping Point, Part II – New DOJ Compliance Counsel
Posted on 13 Oct 2015 by Thomas Fox

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... Read More

Will No One Rid Me of this Meddlesome Priest?
Posted on 27 Jul 2011 by Thomas Fox

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... Read More

Compliance Connected – Line of Sight, Part II
Posted on 23 Oct 2015 by Thomas Fox

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... Read More

FCPA Training: Some Practical Aspects of Resisting a Bribe
Posted on 15 Jun 2011 by Thomas Fox

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... Read More

Fostering Compliance Across Your Company
Posted on 13 Jul 2011 by Thomas Fox

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. ... Read More

Implementing a Values-Based Approach to Your Compliance Program
Posted on 10 Jun 2011 by Thomas Fox

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... Read More

Don’t Fold ‘Em: Making the Case for Ethical Leadership
Posted on 17 Aug 2011 by Thomas Fox

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... Read More

Do As I Say, Not as I Do: IMF and Ethics at the Top
Posted on 31 May 2011 by Thomas Fox

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... Read More

Richard Bistrong: When Corruption Becomes Normal
Posted on 6 Jul 2015 by RBistrong

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... Read More

Lean Knowledge Principles: Application to the Compliance Program
Posted on 28 Sep 2011 by Thomas Fox

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... Read More

Lee Surrenders and Hanson Wade’s Oil & Gas Supply Chain Compliance Conference
Posted on 9 Apr 2015 by Thomas Fox

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... Read More

Using the Octagon: Lozier’s Eight Steps to Further Your Compliance Program
Posted on 22 Aug 2011 by Thomas Fox

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... Read More

Henry II Revisited: The Fair Process Doctrine as a Key Component of a Compliance Program
Posted on 16 Aug 2011 by Thomas Fox

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... Read More

Robert Appleton: It’s FCPA Compliance or Vegas
Posted on 8 Jun 2015 by RBistrong

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... Read More

Branding Your Compliance Project
Posted on 15 Jul 2011 by Thomas Fox

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... Read More

  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: 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 ...
  • Blog Post: 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...
  • Blog Post: 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...
  • Blog Post: Lee Surrenders and Hanson Wade’s Oil & Gas Supply Chain Compliance Conference

    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 Ulysses S. Grant at Appomattox Courthouse,...
  • Blog Post: Robert Appleton: It’s FCPA Compliance or Vegas

    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 and perspective with today’s readers...
  • Blog Post: Richard Bistrong: When Corruption Becomes Normal

    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 hard commercial realities.” Some organizations...
  • Blog Post: Compliance at the Tipping Point, Part II – New DOJ Compliance Counsel

    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 Act (FCPA) unit an additional perspective on best...
  • Blog Post: Compliance Connected – Line of Sight, Part II

    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 in a best practices Foreign Corrupt Practices...