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Dont miss Part 2 of the Measuring ROI series: Using the Net-Present-Value Approach , by Jon Allen The goal of financial management in a company is to maximize the value of the company’s stock. Managers need ways to determine whether a project...

Dont miss Part 1 of the Measuring ROI series: " Using the Payback Approach ", and Part 2: Using the Net-Present-Value Approach , all by Jon Allen The goal of financial management in any company is to maximize the value for its owners. Managers...

I often write about what I call the McNulty Maxims of Compliance. I heard them in a presentation by Paul McNulty to the Houston Chapter of the Texas General Counsel Association in my most recent corporate position. They were (1) What did you do to...

Last week Assistant Attorney General Leslie R. Caldwell spoke at the SIFMA Compliance and Legal Society New York Regional Seminar. In this speech she discussed the new Department of Justice (DOJ) Compliance Counsel. While emphatically noting that this...

Who was Jeannette Rankin and why do we celebrate her today in the context of ethics and compliance? She was the first female to be elected to Congress, as a Representative from Montana in the 1916 elections. In 1917 she was one of 50 votes opposing...

Today I had thought about opening my post with the famous Popeye line " I've had all I can stand, I can't stands no more! " or perhaps ask if Mike Tyson was at the Broncos v. Texans game last Sunday post but I thought that I would begin...

While many companies here in the US complain about the enforcement of the Foreign Corrupt Practices Act (FCPA), and are actively seeking to soften its enforcement by lobbying Congress to amend the FCPA, just imagine how they might feel about paying...

The short autumn of our discontent is over as the United States has ended one of its greatest national convolutions of recent memory. Am I speaking of the attack on the US Consulate in Libya; the current stalemate of US politics and the Presidential race...

In an article in the summer 2011 issue of the Sloan Management Review, entitled, " What Really Happened to Toyota? ", author Robert Cole explored the recent problems of the company and whether these difficulties "throw its legendary manufacturing...

As regular readers of this blog know I often cite the three maxims of Paul McNutly as the basis for a good compliance program. They are the questions that the government will ask when they come knocking: (1) What did you do to prevent it?; (2) What did...

One of my favorite lawyer songs is the Warren Zevon classic " Lawyers, Guns and Money ". I was reminded of that song when I sat on a panel on Wednesday with Dan Chapman and Mike Volkov, where we discussed recent enforcement actions and due diligence...

While there is no shortage of compliance and ethics polls/surveys which populate the newsfeeds, there are two that recently caught my attention, both of which point to the same result, as well stated in The Street, The Bull and The Crisis (published by...

One of the three generally sourced cited as a benchmark of the elements of an effective compliance program is the Organization for Economic Co-operation and Development (OECD) Good Practice Guidance on Internal Controls, Ethics, and Compliance . In...

October 16 th is the anniversary of John Brown's Raid on Harper's Ferry. For those of you not familiar with this episode of American history, abolitionist John Brown led a raid on the US Arsenal at Harper's Ferry, Virginia, the raid was intended...

A couple of weeks ago, I had a guest post from Maurice Gilbert, the Managing Partner at Conselium Partners LP entitled “ Why is it so hard to hire compliance practitioners? ” There were many questions posed to me based upon Gilbert’s...