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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

Brooke Hopkins: But is your compliance program scalable?

The DOJ and SEC haven’t used the word “scalable” to describe an effective compliance program. But they’ve described scalability when talking about what’s needed.

For example, part of the job of the DOJ’s new compliance counsel is to help “assess a company’s program, as well as test the validity of its claims about its program, such as whether the compliance program truly is thoughtfully designed and sufficiently resourced to address the company’s compliance risks.”

And in the FCPA Resource Guide, the DOJ and SEC said: “When it comes to compliance, there is no one-size-fits-all program .… Continue Reading

Action plan: Bring compliance to life in 2016

As you look back on the past year, you will surely find some anti-corruption compliance victories  — even as there are undoubtedly still areas of needed improvement.

As a starting point in the transition to 2016, consider how your program has “matured” over the past year.… Continue Reading

After Bruker: How much compliance is enough?

In the world of anti-corruption internal controls, there is no “one-size-fits-all” model. Ideally, design and implementation of such controls should be thoughtful, rigorous and based on a robust and re-performable corruption risk assessment. 

There are, of course, a number of sources of high-level guidance available, ranging from the DOJ / SEC FCPA Guidance, the OECD’s Good Practice Guidance on Internal Controls, Ethics, and Compliance, Transparency International’s Business Integrity Toolkit, and the UK Ministry of Justice’s Guidance about procedures to prevent bribery, among others.… Continue Reading