When it was signed into law in 1977, the Foreign Corrupt Practices Act was very much an American approach to a global problem: how corruption in general and bribery in particular was skewing international business.… Continue Reading
CCOs know that accountability and discipline are difficult and perilous areas to embed in their programs for a number of reasons.
Decisions involving discipline and internal enforcement involve levers of power that may be viewed as challenges to existing sources of power and “the way things are done around here.”… Continue Reading
In the Justice Department’s new guidance for compliance programs, which appeared online unannounced, undated and unsigned, one detects the experienced hand of the DOJ’s new Compliance Counsel, Hui Chen.
I am so impressed by the content of the Evaluation of Corporate Compliance Programs that I suggest the DOJ rename this document: Evaluation of Corporate Compliance Programs (This Is What True Compliance Subject Matter Expertise (SME) Looks Like). … Continue Reading
Dear FCPA Blog,
I am writing today because I recently learned about the DOJ’s new “Evaluation of Corporate Compliance Programs,” which they released on February 8, 2017 without apparent fanfare. … Continue Reading
How will President Trump and the new administration view compliance officers and their work? Are compliance officers friend or foe?
It’s no secret the election has changed almost everything. A big shake out is coming to America.… Continue Reading
Employees at Wells Fargo opened about two million deposit and credit card accounts that customers didn’t authorize. Why? To earn incentive compensation for new accounts.
So far the bank has fired about 5,300 employees who were involved with the unauthorized accounts and has paid $185 million in fines.… Continue Reading
Major conferences like Compliance Week 2016 are the perfect venue for witnessing the continuing development of the dynamic and fast-evolving compliance profession.
Fresh from presenting the conference’s closing keynote with my “A-team” of panelists, Pat Gnazzo, Keith Darcy and Lee Augsburger, I’ve now had time to reflect on my five big takeaways from the event:
1.… Continue Reading
“I have to believe my compliance work is relevant to this tragedy. I have to believe the mission of compliance can help. If you stay in this transformative work in progress called Compliance 2.0, you have a sense of mission that makes it worth it.… Continue Reading
In my family we knew two of the young people murdered at the Pulse Club in Orlando in the worst mass shooting in American history, with 49 killed and 53 wounded.… Continue Reading
In my last post I discovered the power of images to make a point, like the ribbons of marble floating on air. The Blue Marble, NASA”s image of earth from space, changed how we see the planet, our home.… Continue Reading
The DOJ’s FCPA Guidance and Enforcement Plan places significant emphasis on organizational culture. The section describing “an effective compliance and ethics program” includes “whether the company has established a culture of compliance, including an awareness among employees that any criminal conduct, including the conduct underlying the investigation, will not be tolerated.”… Continue Reading