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How To Demonstrate Ethics and Compliance – Earn It, Re-Earn It and...
What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the...
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Actions Taken During a FCPA Enforcement Action-Lessons from Parker Drilling...
In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they...
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My FCPA and Bribery Act Musings Continue
This past week, my second book, “Best Practices Under the FCPA and Bribery Act” was released. Over the past few years I have tried to provide the compliance practitioner with solid information that can...
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FCPA Prosecutions Against Individuals? Check Out April
One of the oft-heard criticisms of the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) is the lack of individual prosecutions under the Foreign Corrupt Practices Act (FCPA)....
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From the Compact Model to the Luxury Model – Managing Your Third Party Risk
I am currently attending the Hanson Wade Oil and Gas Supply Chain Compliance conference in Houston. The event is excellent and the presentations have been ‘spot on’ for the nuts and bolts of how to do...
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DPAs and NPAs – Useful Tools to Achieve Compliance
The debate on whether the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) has become lively again over the past couple of weeks. Last week, there was a panel hosted...
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Use Planes, Trains and Automobiles to get to Compliance Week 2013
To say I am excited would be putting it mildly. Yes that most premier of compliance related conferences is on the short horizon; Compliance Week 2013 is nearly upon us. It will be from May 20-22 at the...
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Return to the Baker’s Dozen in a Best Practices Compliance Program – Total...
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran. At this point, the settlement documents consist of the Deferred Prosecution Agreement (DPA),...
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We Say Good-Bye to the Secretary of Defense and Total Says Hello to Two...
Today I finalize my review of the Total SA (Total) Foreign Corrupt Practices Act (FCPA) enforcement action. However, before I do so, I would like to commemorate this date and one person who left us...
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Some Thoughts on What Makes a Good CCO
There are several prominent commentators who frequently discuss the role a Chief Compliance Officer (CCO). One such commentator is Donna Boehme, who regularly writes articles, speaks about, and even...
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Gettysburg Day 2: Dan Sickles, Political Generals and the CCO Position
Day 2 at Gettysburg saw the fighting swing south of the village, along a ridge line that formed a fishhook at its end on an outcropping called the Little Round Top. This was the far south end of the...
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Significant FCPA Enforcement Actions in 2013 – Individuals
77 years – that is how long Great Britain went without a native son winning the Men’s Singles title at Wimbledon. This past Sunday that drought ended when Andy Murray won the coveted trophy in a...
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Code Words for Bribery and Corruption Across the Globe
Life sometimes imitates art. Remember the Orthofix enforcement action, where the company used the used the code word chocolates to identify the bribes it paid? This lead to the memorable quote from...
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Not Draconian – Gift, Travel and Entertainment Under the FCPA
The Greek ruler Draco has received some very bad PR advice over the centuries. After all, it is his name which is the root for our word draconian. Draco is credited with committing to writing the first...
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Astros Swept Again – Is a China Sweep Coming Next?
What is a sweep? It is certainly a well-known and relevant term in the sporting world. This past weekend, the utterly inept Houston Astros were swept by the Seattle Mariners in a three game series....
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A Farewell to Dr. Randolph and Making Your Compliance Program Effective
Dr. Henry Randolph died this week. He was a well-known expert in the field of dairy science. He was from a small town in Tennessee, obtained his PhD from the Ohio State University, moved on to teach at...
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Bad Things Come In Threes for CCOs
It is often said that bad things come in threes. I have often wondered where this phrase came from. So I checked out Wikipedia, no luck there. How about trying Google as the harbinger of all knowledge?...
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Where’s The Ball? Lesson for the Compliance Practitioner in China
Where’s the ball? That iconic question was asked by Oakland A’s center fielder Chris Young to Houston Astro left fielder Robbie Grossman near second base late Wednesday night, as Grossman was returning...
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Welcome Back My Friends To The Show That Never Ends
Welcome back my friends, to the show that never end; We’re so glad you could attend, come inside, come inside; There behind the glass stands a real blade of grass; Be careful as you pass, move along,...
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What is the Fabric of Compliance?
The goal of any company regarding its compliance regime should be to make compliance a part of the fabric of your company and the face that you present to the world. That was the message from the...
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