At the recently concluded Compliance Week 3rd Annual Third-Party Risk Management Conference, Kara Brockmeyer, former head of the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) unit and now partner at Debevoise & Plimpton LLP, said that if there is no business reason to contract with a third party, this is more than [...]
In this episode I have back Dr. Marsha Ershaghi Hames, the Managing Director, Strategy at LRN. We discuss how leading with principles has become even more important after the current wave of corporate scandals all in the context of board accountability. Some of the topics we discuss in this episode include: What is Board accountability? [...]
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The leadership lessons from the race to the South Pole renewed my interest in leadership for the compliance practitioner. In a New York Times (NYT) article, entitled “Lincoln’s School of Management”, Nancy F. Koehn, a historian at the Harvard School of Business, wrote about Lincoln’s experience in drafting and issuing the Emancipation Proclamation as “one [...]
In this episode, Matt Kelly and I take a deep dive into the recent SEC enforcement action against Elizabeth Holmes, the disgraced founder of Theranos, for her massive fraud around the former unicorn. Holmes claimed to have developed a proprietary system of blood testing so that with only one pin-prick of blood over 200 diagnostic [...]
The post Compliance into the Weeds-Episode 75, SEC Enforcement Action Against Holmes appeared first on Compliance Report.
The golden age of polar exploration lasted from about 1895 to 1912 during which time explorers raced to reach both the North Pole and South Pole. Even today those explorations and expeditions raise admiration and awe. Today, I want to discuss the race to the South Pole and what leadership lessons may be drawn from [...]
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Vince Walden is a partner at Ernst & Young, and he’s passionate about anti-fraud, anti-corruption and compliance-related analytics and innovations. Today, Vince and Tom talk about some of the innovative strategies he’s developing for General Electric. From training and retention to automation and relevance, accurately observing behavior through data analytics is the key to compliance. [...]
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As the Compliance Evangelist, one of the most exciting things about practicing in the compliance space is the continual innovation I have seen since 2007. All parties to compliance, the regulators, corporations, services providers and vendors, continually innovate. Everyone has a role in this innovation process. Compliance itself has moved from a largely paper program, [...]
In this episode, I welcome back Steve Durham, a partner with Labaton and Sucharow to discuss the continued reverberations from the recent Supreme Court decision narrow the definition of whistleblowers in Digital Realty Trust v. Somers. Durham discussed the impact the decision may portend for the SEC Office of the Whistleblower and both the quality [...]
The post FCPA Compliance Report-Episode 375, Steve Durham on Impact of Digital Realty Trust appeared first on Compliance Report.
Brainstorming can be a useful and indeed powerful tool in the business world. In my corporate career I participated in several large brainstorming sessions to help develop or focus on new product or service initiatives. Typically we were brainstorming for answers. Yet I recently read an article in the Harvard Business Review (HBR), entitled “Better [...]
March Madness is upon us, with the first ever #16 knocking off a Number 1 see. In the midst of this true madness, Jay Rosen and myself take a look at some of the top compliance stories over the past week. March Madness is here. So is corruption in NCAA basketball. Tom considers both stories [...]
The post This Week in FCPA-Episode 94, the March Madness edition appeared first on Compliance Report.
If you watched the end of the Loyola-Chicago-Miami game, you are well aware that March Madness is officially here. I was barely functioning during the second half of the Gonzaga-UNCG game, having picked the Zags into my Final Four this year but at least they held on. About the best I can say is that [...]
The post Join us for Ethics Madness II – Games, Live Tweets and Ethics appeared first on Compliance Report.
Black holes lost a mentor yesterday as Stephen Hawking died. While Hawking’s stature no doubt merits a full blog post on its own, when someone holds the same academic chair as Sir Isaac Newton and also plays himself on an episode of Star Trek: The Next Generation; there is probably not much more that can [...]
Henry Worsley and Ernest Shackleton are related by more than blood. They are related by their souls. A distant relative, Frank Worsley had accompanied Shackleton on his Antarctic expeditions, including the abortive Nimrod expedition where Shackleton had tried and failed to reach the South Pole coming with 90 miles of reaching his goal until he [...]
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Henry Worsley and Ernest Shackleton are related by more than blood. They are related by their souls. A distant relative, Frank Worsley had accompanied Shackleton on his Antarctic expeditions, including the abortive Nimrod expedition where Shackleton had tried and failed to reach the South Pole coming within 90 miles of reaching his goal until he [...]
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In this episode, Matt Kelly and I continue our exploration of the fallout from the recent Supreme Court decision in Digital Realty Trust v. Somers in light of the filing by BioRad in its appeal of the whistleblower award to its former General Counsel, Sanford Wadler. Wadler had internally reported allegation of FCPA violations by [...]
The post Compliance into the Weeds-Episode 74, Continued Fallout from Somers appeared first on Compliance Report.
The bane of every first-year law student, at least in Civil Procedure, is Pennoyer v. Neff. This is because (1) it is usually studied very early in the semester; (2) is viewed as the first true introduction to how strikingly convoluted legal issues can be; and (3) has the most turgid legal writing from the [...]
The post Farewell to John Reed, the Death of Pennoyer v. Neff and the Elbit FCPA Enforcement Action appeared first on Compliance Report.
In this episode, I visit with Miller & Chevalier Member John Davis on the firm’s FCPA Winter Review 2017. We discuss the key FCPA enforcement actions from 2017 and developments in compliance. Davis identifies four theme’s from Miller’s report including: (1) What if any change did the new administration bring in FCPA enforcement; (2) the [...]
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As most of you know, when I get interested in something I can get carried away writing about it and it has happened again as I have been exploring the intersection of agile concepts for business processes and operationalization of compliance. The more I study agile and how agile concepts apply to the corporate compliance [...]
The post Agile Compliance = Operationalized Compliance: Part III – Incentives, Recruiting and Development appeared first on Compliance Report.
In this episode, Jay Rosen and myself take a look at some of the top compliance stories over the past week, including some fury. Wells Fargo is having its soul investigated by actual nuns. Alistair Gray reports in the Financial Times; Thorton McEnery notes sometimes the Universe is both hilarious and cruel in Dealbreaker; and [...]
The post This Week in FCPA-Episode 93, the Hell Hath No Fury edition appeared first on Compliance Report.
I continue my exploration of how an agile approach can bring innovation to a corporate compliance function. Yesterday I considered how agile concepts can be used to more fully operationalize a compliance function through coaching to and for middle managers. Today I want to explore how agile can more fully operationalize a compliance program by [...]
The post Agile Compliance = Operationalized Compliance: Part II – Compliance Teams appeared first on Compliance Report.