Corporate

Recent Posts

Ethics in Business: How to Avoid the “Road to Ethical Damnation.”
Posted on 30 Jun 2015 by RBistrong

Of the many periodicals I read and review, I always look forward to Business Compliance , and specifically to the Round Table discussions, where I have had the pleasure and honor of being a prior contributor. This quarter brings another compelling array... Read More

Haas School Training for Compliance and Ethics Leadership
Posted on 8 Feb 2012 by Thomas Fox

There are a myriad of compliance and ethics conferences across the country each year. I regularly attend and speak at some of these. There are also more regular webinar and local events which may focus on specific topics or themes. However, there are... Read More

Trip to Annapolis and Teaching Leadership
Posted on 27 May 2014 by Thomas Fox

Monday was Memorial Day and is the day wherein the men and women who died while serving in the United States Armed Forces are remembered. The holiday is celebrated every year on the final Monday of May . The first recorded Memorial was held on May 1,... Read More

Channeling Yogi Berra to Find Smart Risk in Compliance
Posted on 25 Sep 2015 by Thomas Fox

Yogi Berra died yesterday. In addition to being one of the greatest catchers in baseball, he was a 3-time Most Valuable Player (MVP), a 15-time All Star, a Hall of Famer and member of the All-Century Team, a player on 10 World Series champions and Manager... Read More

How to Build a Culture of Ethics and Compliance: the Greatest Article Ever – Part III
Posted on 11 Sep 2013 by Thomas Fox

Today I conclude my exploration of the article in the summer 2013 issue of the MIT Sloan Management Review, entitled “ Designing Trustworthy Organizations ”, by the quartet of authors: Robert F. Hurley, Nicole Gillespie, Donald L. Ferrin and... Read More

Gettysburg Day 3 – Failure of QA/QC and the Evolution of Your Compliance Program
Posted on 4 Jul 2014 by Thomas Fox

Thursday was the 151 st anniversary of Day 3 of the Battle of Gettysburg. Last year I focused on Pickett’s Charge and lessons that a compliance practitioner might draw from it. This year I want to look at the Confederate artillery bombardment, which... Read More

Gettysburg Day 2 – A Failure of Culture in Leadership and How to Overcome It
Posted on 3 Jul 2014 by Thomas Fox

Today is the 151 st anniversary of Day 2 of the Battle of Gettysburg. Last year I focused on Union General Dan Sickles and how is disobeying of his commanding officer’s order, destroyed his brigade and ended his military career. Today, I want to... Read More

How a Failure to Set Tone-at-the-Top Led to a Fractured Vertebra
Posted on 8 Jul 2014 by Thomas Fox

What does ‘Tone-at-the-Top’ mean to any anti-bribery or anti-corruption program? Conversely, what if management says to do the right thing but only judges employees on their sales; what is the message that only ‘Talking The Talk’... Read More

Unofficial Messages-Creating a Culture of Compliance
Posted on 7 Feb 2012 by Thomas Fox

An article in the January/February issue of the SCCE magazine, entitled " An ethical corporate culture goes beyond the code ", author Dawn Lomer argues that the unofficial message which a company sends to its employees "is just as... Read More

March Madness and Discipline Under the FCPA
Posted on 8 Apr 2013 by Thomas Fox

Tonight is the finals of the NCAA Men's Basketball Tournament, known as March Madness. As I went to law school at the University of Michigan, I will be pulling for the Wolverines to win the big game. If you are not a Louisville or Big East fan... Read More

The Most Profitable Baseball Team of All-Time and Commitment to Ethics and Compliance
Posted on 29 Aug 2013 by Thomas Fox

Sorry to interrupt my three-part series on the greatest ethics and compliance article ever written but I just could not help myself. On Monday, forbes.com, in an article entitled “ 2013 Houston Astros: Baseball’s Worst Team Is The Most Profitable... Read More

Lessons Learned on Compliance and Ethics
Posted on 14 Feb 2012 by Thomas Fox

When my daughter was 7 she wrote and published her first book. When I asked her how she did it, she replied "Dad, it's easy to write a book, you just sit down and do it." I thought about that sage wisdom for many years before I sat down... Read More

Gettysburg Day 2 – A Failure of Culture in Leadership and How to Overcome It
Posted on 3 Jul 2014 by Doug Esten

Today is the 151 st anniversary of Day 2 of the Battle of Gettysburg. Last year I focused on Union General Dan Sickles and how is disobeying of his commanding officer’s order, destroyed his brigade and ended his military career. Today, I want to... Read More

The Story of Ajax: Fairness in Rewarding Employee Behaviors
Posted on 15 Mar 2012 by Thomas Fox

How does your company deal with the question of fairness in its compliance program? I thought about that question while reading an article in the New York Times (NYT), entitled " That Eternal Question of Fairness ", by Nancy Koehn. In her... Read More

Why the Compliance Function is Different Than the Legal Function
Posted on 9 Jun 2014 by Thomas Fox

I have long been proud of my profession. I would often tell students that they were about to join a profession which extended as far back as Demosthenes, who practiced his closing orations against crashing sea waves so that the full Greek demos might... Read More

  • Blog Post: How Charles Ponzi Can Inform Your Compliance Program

    Yesterday, I used some of the wisdom from current CIA Director General David Petraeus to suggest how senior management might move forward with a compliance program. Today I will use a very different individual to help inform your third party due diligence, Charles Ponzi. My colleague Tracy Coenen...
  • Blog Post: Unofficial Messages-Creating a Culture of Compliance

    An article in the January/February issue of the SCCE magazine, entitled " An ethical corporate culture goes beyond the code ", author Dawn Lomer argues that the unofficial message which a company sends to its employees "is just as powerful-if not more powerful-than any messages carried...
  • Blog Post: Haas School Training for Compliance and Ethics Leadership

    There are a myriad of compliance and ethics conferences across the country each year. I regularly attend and speak at some of these. There are also more regular webinar and local events which may focus on specific topics or themes. However, there are relatively few educational programs, put on by...
  • Blog Post: Creating Sustainable (Compliance) Performance

    Compliance practitioners are continually tasked with moving a company's culture of compliance forward. However, the day-to-day work is sometimes too granular to see results. In an article in the January-February issue of the Harvard Business Review , entitled " Creating Sustainable Performance...
  • Blog Post: Lessons Learned on Compliance and Ethics

    When my daughter was 7 she wrote and published her first book. When I asked her how she did it, she replied "Dad, it's easy to write a book, you just sit down and do it." I thought about that sage wisdom for many years before I sat down and started writing this blog. While I did not...
  • Blog Post: How FATF Recommendations on Anti-Money Laundering Inform Your Compliance Program

    The Financial Action Task Force (FATF) is an inter-governmental body established in 1989 by the Ministers of its Member jurisdictions. Its mandate is to set standards and to promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing...
  • Blog Post: The CCO and Crisis Management

    "What, Me Worry?" is one of my favorite all-time slogans. Anyone who grew up on the 60s or 70s recognizes this comes from Alfred E. Neuman, the enigmatic face of Mad Magazine. While this phrase certainly had its uses for us teenagers back then, it is not a by-word for how the compliance...
  • Blog Post: The Story of Ajax: Fairness in Rewarding Employee Behaviors

    How does your company deal with the question of fairness in its compliance program? I thought about that question while reading an article in the New York Times (NYT), entitled " That Eternal Question of Fairness ", by Nancy Koehn. In her article, Koehn discussed the book " The Ajax...
  • Blog Post: Mendelsohn and Denniston: A Compliance Dialogue

    Last week I attended the 2012 Global Ethics Summit hosted by Ethisphere. The first event was a conversation between Mark Mendelsohn and Brackett Denniston, Senior Vice President and General Counsel of General Electric (GE). They both had some interesting observations on the current state of Foreign...
  • Blog Post: Chesapeake Lighthouses and Lighting the Way for Compliance

    In the winter 2013 issue of the Colonial Williamsburg magazine is an article by Michael Lombardi, entitled " Lighthouses Marked the Shoals of the Commerce Clause ". In this article, Lombardi wrote about four lighthouses authorized by Congress in the late 18 th and early 19 th century to...
  • Blog Post: March Madness and Discipline Under the FCPA

    Tonight is the finals of the NCAA Men's Basketball Tournament, known as March Madness. As I went to law school at the University of Michigan, I will be pulling for the Wolverines to win the big game. If you are not a Louisville or Big East fan I hope that you can pull for us or at least throw...
  • Blog Post: I Am Legend: Richard Matheson and Ethics in Your Compliance Program

    Richard Matheson died on Sunday. I read his book “ I Am Legend ” when I was a very young teenager. It was my first real introduction into science fiction and I instantly became a fan of Matheson. It spoke to me about being an outsider and feeling completely out of place, as was the protagonist...
  • Blog Post: How to Build a Culture of Ethics and Compliance: The Greatest Article Ever – Part I

    Donna Boehme and Jim McGrath continually rail against the notion that a ‘rogue employee’ causes the majority of bribery and corruption charges under such laws as the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act. Companies continually claim that they do business ethically and in...
  • Blog Post: The Most Profitable Baseball Team of All-Time and Commitment to Ethics and Compliance

    Sorry to interrupt my three-part series on the greatest ethics and compliance article ever written but I just could not help myself. On Monday, forbes.com, in an article entitled “ 2013 Houston Astros: Baseball’s Worst Team Is The Most Profitable In History ”, Dan Alexander reported...
  • Blog Post: Send in the Clowns – the NCAA and its Investigation of Johnny Football

    How can you determine if an organization charged with compliance is corrupt or simply incompetent? It is hard today to answer that question when it comes to the National Collegiate Athletic Association (NCAA) and its enforcement division. For those of you do not know the story, the NCAA was investigating...
  • Blog Post: How to Build a Culture of Ethics and Compliance: the Greatest Article Ever – Part II

    In this post I continue my exploration of the article in the summer 2013 issue of the MIT Sloan Management Review, entitled “ Designing Trustworthy Organizations ”, by the quartet of authors: Robert F. Hurley, Nicole Gillespie, Donald L. Ferrin and Graham Dietz. In case you missed Part I...
  • Blog Post: How to Build a Culture of Ethics and Compliance: the Greatest Article Ever – Part III

    Today I conclude my exploration of the article in the summer 2013 issue of the MIT Sloan Management Review, entitled “ Designing Trustworthy Organizations ”, by the quartet of authors: Robert F. Hurley, Nicole Gillespie, Donald L. Ferrin and Graham Dietz. In case you missed the previous articles...
  • Blog Post: The Red Baron and Leading in Compliance

    For anyone who grew up in the 60s or 70s; the comic strip adventures of Snoopy vs. the Red Baron were legendary. ‘ Curse You Red Baron’ was a routine line from Snoopy as he was foiled time and time again by the Red Baron. Anyone who has seen “ Charlie Brown and The Great Pumpkin ”...
  • Blog Post: Will World Cup 2022 Become World Cup 2023?

    SPOILER ALERT – This article reveals that the temperature becomes quite hot in Qatar in the summer months. That paragon of compliance and ethics, the world’s richest and most influential single-sport ruling body Fédération Internationale de Football Association (FIFA), has...
  • Blog Post: Dan Snyder, the CCO and Doing Business Ethically

    We continue the football theme as an entrée into compliance by looking at Washington Redskins owner Daniel Snyder. I am a life-long Dallas Cowboys fan so having someone like Snyder as the owner of your main rival at the professional level is almost too much fun for words. Clearly presaging the...
  • Blog Post: Trip to Annapolis and Teaching Leadership

    Monday was Memorial Day and is the day wherein the men and women who died while serving in the United States Armed Forces are remembered. The holiday is celebrated every year on the final Monday of May . The first recorded Memorial was held on May 1, 1865 in Charleston, South Carolina to commemorate...
  • Blog Post: Why the Compliance Function is Different Than the Legal Function

    I have long been proud of my profession. I would often tell students that they were about to join a profession which extended as far back as Demosthenes, who practiced his closing orations against crashing sea waves so that the full Greek demos might hear him when he closed a trial. Further, while thoughts...
  • Blog Post: The Magna Carta and Scrutiny of Your Compliance Program

    Yesterday, June 15 was Father’s Day so for all us fathers out there, it was our day and I hope that you enjoyed and cherished it. It was also the anniversary of what I believe was one of the greatest achievements in Anglo jurisprudence, the signing of the Magna Carta, by King John and the Barons...
  • Blog Post: Gettysburg Day 1 – Stepping Back to See the Whole Picture

    Last year I did a three-day series on the Battle of Gettysburg and looked at some lessons that are applicable to a modern day compliance practitioner. As not only did I learn quite a bit about the battle, it seemed to strike a chord with many readers so this year I will continue the tradition. Today...
  • Blog Post: Gettysburg Day 2 – A Failure of Culture in Leadership and How to Overcome It

    Today is the 151 st anniversary of Day 2 of the Battle of Gettysburg. Last year I focused on Union General Dan Sickles and how is disobeying of his commanding officer’s order, destroyed his brigade and ended his military career. Today, I want to focus on the Confederate side and how the non-use...