I’d been retired from the FBI for a couple years and was working near Richard in Connecticut at a large hedge fund.… Continue Reading
What’s the biggest change in the compliance landscape? It’s the deep engagement of boards and senior management.
Today they understand the risks of reputational damage and want to stay a step ahead of the compliance process.… Continue Reading
Mastercard took that to a new level when they engaged a production company to depict chapters of my own FCPA violations, eventual guilty plea, and my sentencing to fourteen and a half months in prison.… Continue Reading
My Federal Probation formally terminated on January 14, and with that termination came the return of my passport.
My ten-year crucible in the criminal justice system began when the DOJ targeted me in 2007 — with only myself to blame.… Continue Reading
The real world isn’t just good guys and bad guys. There’s a story behind every compliance problem, and even though it may not excuse anyone’s behavior, it should be a reminder that people just like us make mistakes — sometimes really big mistakes.… Continue Reading
I’ve noticed a positive shift in corporate compliance events, especially during some of my overseas engagements. Compliance initiatives and ethical messages are coming directly from business leaders in addition to compliance executives.… Continue Reading
When compliance leaders ask, “What can I do to better connect with the work-force?” my response is always the same. I encourage them to show their vulnerability.
How? By recognizing that no one experiences risk more than the people who work in the middle of it, and that sometimes even a well-intentioned compliance program can miss that risk.… Continue Reading
At the Federal Prison Camp in Lewisburg PA where I spent fourteen and a half months, one personal liberty inmates were allowed was reading. Under Bureau of Prison rules, hardcover books could be sent directly to inmates from the distributor, e.g.… Continue Reading
Barry Vitou, a partner in Pinsent Masons in London and head of their Global Corporate Crime Team, talked with me this week about the future of the SFO.
We also talked about the “Blockbuster Funding” the SFO uses for special investigations, morale at the organization, and the challenges the SFO faces dealing with the press, public, and its government masters.… Continue Reading
Marketing and sales people working in low-integrity places are usually far removed from the victims of nearby corruption. Compliance professionals supporting a far-flung work force need to keep that cultural isolation in mind.… Continue Reading