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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

ISO 37001: Not all certifications are created equal

On January 25, 2017, Eni Corporation announced its ISO 37001 certification. The press release stated that “certification confirms the quality of the system of rules and controls aimed at preventing corruption, developed by Eni since 2009 in line with the principle of ‘zero tolerance’ expressed in its Code of Ethics.”

Two weeks later the company’s CEO and his predecessor were charged with international corruption by Italian prosecutors following an investigation into the company’s 2011 purchase of a Nigerian exploration license.… Continue Reading

Three predictions for the future of ISO 37001

2018 was an eventful year in ISO 37001’s adoption journey. The anti-bribery standard’s flexibility was demonstrated through a variety of first-time (for ISO 37001) public and private sector uses.

The Brazilian and Danish prosecutors’ use of ISO 37001 in bribery settlement agreements, and the Korean Pharmaceutical and Bio-Pharma Manufacturers Association assistance to its 194 members with a phased ISO 37001 adoption approach, for example. 

 Brazil, Italy and Peru lead in terms of the number of certified ISO 37001 organizations.… Continue Reading

Will ISO 37001 become a box-checking formality?

My prior post for the FCPA Blog suggested that changes are needed to the ISO 37001 anti-bribery management system before countries, agencies, and companies move forward with large-scale adoption.

One of my suggestions in particular — that ISO replace certification with a process for obtaining reviews of compliance programs — attracted thoughtful opposing comments and some criticism.… Continue Reading

ISO 37001: Let’s ask some tough questions

The debate about the ISO 37001 anti-bribery management system hasn’t gone away. Compliance professionals are still asking tough questions.

Does certification matter? Is it just PR or will it save or help the company if we have a problem?… Continue Reading

Kevin Bogdanov: How automation will shape FCPA compliance in 2018

2017 proved to be a blockbuster year for the FCPA and anti-bribery and corruption (ABC) enforcement at large.

From sustained record levels of enforcement (some 11 penalties levied, totaling $1.92 billion; the second largest year on record) to significant developments via the newly announced FCPA Corporate Enforcement Policy by the Department of Justice in late November, businesses are on notice that this remains a significant regulatory priority.… Continue Reading

Worth MacMurray: New DOJ enforcement policy and ISO 37001 are aligned

In Deputy Attorney General Rosenstein’s recent announcement of a new FCPA Policy, he highlighted three hallmarks of a Policy effective compliance program: fostering a culture of compliance; dedicating sufficient resources to compliance activities; and ensuring that experienced compliance personnel have appropriate access to the board.… Continue Reading

Kristy Grant-Hart on ISO 37001: Who’s doing the certifying (and other responses to Hui Chen)

Hui Chen recently published a post sharing her opinions on the ISO 37001 Anti-Bribery Management Standard and ISO 37001 certification. She made some important points. 

She also asked questions and drew comparisons that should be evaluated in the context of how the ISO 37001 certification process occurs, and what it means for companies and organizations seeking it.… Continue Reading