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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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

In honor of the return of Sherlock Holmes to PBS with Season 3, I begin a week of Sherlockian themed posts. Today we consider the quality of justice that Holmes discussed in The Abbey Grange , he allowed a man who murdered a wife-abusing husband to go...

Last week, I observed one of the worst actions by a major league sports commissioner in my lifetime. Not the worst, as I will give that "worst award for a decision made by a sports commissioner in my lifetime", to either of two Baseball Commissioners;...

Can you synthesize and reconcile the world's leading laws, regulations and commentaries on the best practices an anti-bribery and anti-corruption compliance program? I recently saw one such approach by Paul McNulty and Stephen Martin of the law firm...

For those of you who do not believe that global warming is upon us, let me assure you that it is real and unfortunately caused by humans. How do I know this for a certainty? It is because there was an event back in 2005 that caused Hell itself to freeze...