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The Sussex Vampyre and the ADM FCPA Settlement
Today I want to use the story of The Sussex Vampyre as the starting point for an inquiry into the recent Archer-Daniels-Midland Corp (ADM) Foreign Corrupt Practices Act (FCPA) enforcement action. In...
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Who Had the Worse Day – Peyton Manning or Banks and Investment Funds?
The Seattle Seahawks gave the Denver Broncos an old-fashioned tail-whoopin’ in Super Bowl history on Sunday. I admit that I was pulling for the old guy, Peyton Manning to pull out another one but I did...
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The FCPA and Fight Against Terrorism
I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion in Department of Justice (DOJ) and Securities and Exchange Commission (SEC) enforcement of the...
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Board Investigations and the Curse of the Mummy’s Tomb – Part II
Yesterday I began an exploration of a recent article in the Corporate Board magazine, entitled “Successful Board Investigations” by David Bayless and Tammy Albarrán, partners in the law firm of...
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How Does the 20th Amendment Inform Your Compliance Program Incentives?
On this date in 1933, FDR held his first inauguration. It was also the final inauguration held in March before the passage of the 20th Amendment to the US Constitution that moved the inauguration date...
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Join Us For Hanson Wade’s Compliance Strategy Day
One of the best annual compliance and ethics conferences returns to Houston next month when Hanson Wade presents its 4th Annual Oil & Gas Supply Chain Compliance Community Week from April 14-17....
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Life Cycle of Third Party Management – Step 1 Business Justification
With thanks to the Two Tough Cookies, I am back from a successful Spring Break college tour to universities in the state of Washington. My daughter and I had a great time, experienced some typical and...
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Life Cycle Management of Third Parties – Step 5 – Management of the Relationship
Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On...
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Mickey Rooney and The 90 Cent Solution
We begin today with a word on the death of Mickey Rooney. Rooney’s career, spanning nearly 90 years was certainly was from a different era. He was short of stature and long in his number of marriages...
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The HP FCPA Settlement
Last week the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly announced the conclusion of a Foreign Corrupt Practices Act (FCPA) enforcement action against...
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Implementing Compliance Incentives In Your Company
Several readers have asked why I have not written anything about the Houston Astros this year. The answer is two-fold. The first is that I really do not care. However, the more I thought about it, the...
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Gifts, Travel and Entertainment Under the FCPA – Part II
Ed. Note – I know yesterday I said this would be a two-part series but as usual I got carried away so it has become a three part series. Today I review the Opinion Releases and Enforcement Actions...
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Gehrig’s Streak Ends and Compliance Week 2014 Is Near
Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive...
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What Does an Effective Compliance Program Look Like? – The Regulators...
What does an effective compliance program look like? Is it one that follows the Ten Hallmarks of an Effective Compliance Program as set out in the 2012 FCPA Guidance? How about one that uses the Six...
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Mid-Year FCPA Report, Part I
As we are now past the halfway mark of 2014, I thought it might be a good time to look at the year in review, so over the next couple of days, I will be reviewing what I believe to be some issues and...
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Nixon Announces Resignation; GSK Just Resigns
On this day, 40 years ago, President Richard Nixon announced that he would resign the Office of the President, effective the next day on August 9 at noon. I can still remember my father instructing us...
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Board of Directors and FCPA Oversight – An Internal Control Under SOX, Part II
In Part I of this two-part post regarding a Board of Director’s Role in Foreign Corrupt Practices Act (FCPA) oversight from the internal controls perspective, I reviewed how a Board might have...
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Carlton Fisk, The Homer and Oversight of a Profitable Subsidiary
Today we celebrate one of the great moments in World Series history. At approximately at 12:34 AM on this date in 1975, Carlton Fisk came to bat at the bottom of the 12th, in Game 6 of the World Series...
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The Great Pumpkin and the Alternative Universe
For Halloween last year, I wrote a blog post where I derided Linus and his forlorn quest to have his pumpkin patch named the most sincere by the Great Pumpkin. In response I received this rather terse...
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Gordon Lightfoot, the Edmund Fitzgerald and the Bio-Rad FCPA Settlement, Part I
This month there are two dates that are forever tied together in the annuals of maritime tragedies and great songwriters. November 10 is the 39th anniversary of the sinking of the Great Lakes freighter...
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