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Social Media Week Part V – Tools and Apps for the Compliance Practitioner

To conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next week.) You need to remember that your compliance customer...

A Summer of Compliance

When I was working in the field of international sales, August was typically a month of ‘down time’ as a combination of end user, third party and corporate holidays marked a lull in summer sales activity. Well, I have not experienced such a drop-off in the world of anti-bribery compliance...

Social Media Week Part VI – Social Media and CCO 3.0

I conclude this exploration of the uses of social media in doing compliance by exploring why the compliance function is uniquely suited to using social media tools. Long gone are the days when Chief Compliance Officers (CCO) or compliance practitioners were lawyers housed in the Legal Department or the...

Amazon’s Culture, the Greatest Brawl in Baseball and Compliance

One of the strangest incidents in the history of Major League Baseball (MLB) recently had its 50 anniversary. It involved a brawl between Hall Of Fame pitcher Juan Marichal and catcher John Roseboro. The game was between the then (and still) heated rivals San Francisco Giants and Los Angeles Dodgers...

The Mini Cooper and Project Execution in Compliance

The price of oil hovers near $40 per barrel. There are all manner of responses suggested to this drop from nearly $100 per barrel just a short time ago. Yet the price of oil has long been much more than a political conversation, sometimes it leads to innovation. Today we celebrate the birth of the British...

Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Daryl Dawkins died yesterday. To anyone who followed the National Basketball League (NBA); Dawkins will always be remembered with the brilliant Stevie Wonder-derived moniker – Chocolate Thunder . I will also remember him for three things. First he was one of the very rare high school stars who...

Hiring in Compliance – Part I: Developing the Job Profile and Criteria

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 guest post. This led me to propose to Gilbert a series...

Hiring in Compliance, Part II – Candidate Sourcing

This week I am presenting a series on hiring in the compliance industry based on interviews I did with Maurice Gilbert, the Managing Partner at Conselium Partners LP. These interviews will be broadcasted on my podcast site, fcpacompliancereport.com, my YouTube channel – FCPA Compliance and Ethics...

Hiring in Compliance, Part III – Presentation of Job Opportunity to Potential Candidates

This week I am presenting a series on hiring in the compliance industry based on interviews I did with Maurice Gilbert, the Managing Partner at Conselium Partners LP. These interviews will be broadcasted on my podcast site, fcpacompliancereport.com, my YouTube channel – FCPA Compliance and Ethics...

Hiring in Compliance, Part IV: The Interview Process

I continue my series of blog posts on the hiring process in the compliance field based on a series of interviews I did with Maurice Gilbert, the Managing Partner at Conselium Partners LP. These interviews are being broadcasted on my podcast site, fcpacompliancereport.com, my YouTube channel – FCPA...

Hiring in Compliance, Part V: The Offer and Conclusion

I conclude my series of blog posts on the hiring process in the compliance field, which have been based on a series of interviews with Maurice Gilbert, the Managing Partner at Conselium Partners LP. These interviews are being broadcasted on my podcast site, fcpacompliancereport.com , my YouTube channel...

Agatha Christie and Building Ethical Culture in an Organization

On this day in 1890, Mary Clarissa Agatha Miller, who later became known as Agatha Christie, was born in Torquay, Devon, England. As a youngster, she and her sister, Madge, made up thrilling stories to tell each other. As noted in ‘This Day in History’, while her husband, Colonel Archibald...

Design Thinking in Compliance

In many ways the migration from Chief Compliance Officer (CCO) 1.0 to 2.0 and beyond is more than simply about the technical aspects of a CCO to the internal and external delivery of a compliance solution by the compliance function. The Department of Justice (DOJ) and Securities and Exchange Commission...

A Remarkable Listener Experience in Compliance

I listen to several podcasts each week and one of my favorites is ‘The Showrunner’ podcast, co-hosted by Jerod Morris and Jon Nastor. While the basic premise is a podcast about podcasting, I have found it to be much broader than that simple premise. In many ways it is about the craft of communication;...

VW Emissions Testing Scandal – View From the Board

The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “ Problems at VW Start at the Boardroom ”, James B. Stewart was unremitting in his criticism of the VW Board, when near...

Astros in the Playoffs, Will Hell Freeze Over?

When recently I contacted the Underworld about the potential listing of this vast property, I was stunned when Satan himself answered the phone. While I was tempted to ask what happened to all his hired help down there, Satan, being much more direct, got immediately to the point and said his action was...

Compliance at the Tipping Point, Part I – The Yates Memo

This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as his heritage day. My little sister was also born on the same calendar day, so here is to my grandfather...

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...

Compliance at the Tipping Point, Part III – The VW Emissions-Testing Scandal

I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other commentators have written about the VW scandal from a variety of angles...

Compliance at the Tipping Point, Part IV – The Schrems Decision

I continue my exploration of why I believe that compliance is at the Tipping Point, with today’s entry of data point four, which is last week’s decision by the European Court of Justice (ECJ) in the Schrems case. While most commentators have focused on the Schrems decision around the lack...

Compliance at the Tipping Point, Part V – Protection Afforded From a Compliance Program

Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows , producer Val Lewton, whose films for RKO had some of the most interesting and innovative use of techniques to induce horror that have been...

Compliance Connected – Line of Sight, Part I

Sometimes the simplest visual can provide the greatest insight about transformation. I had that particular insight when I recently had the chance to catch up with Scott Lane, Chief Executive of the Red Flag Group, at the SCCE 2015 Compliance and Ethics Institute. In a podcast Lane talked about the line...

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...

Goodbye to Fred Thompson – What’s Your Compliance Plan?

Fred Thompson died this week. He had a long and distinguished government career including working in the Senate Watergate Committee as a staffer. Thompson was credited for coming up with the signature question from the Watergate hearings, uttered by then Tennessee Senator Howard Baker who asked, “What...

Caldwell Lays It Out – DOJ Metrics for a Compliance Program

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 new position was not an explicit or even tacit recognition...