FCPA Compliance & Ethics

Countdown to GDPR-Episode 6, GDPR for Communications Professionals

In this episode of Countdown to GDPR, Jonathan Armstrong and myself are interviewed by Laura Petrolino, the Chief Client Officer at Arment Dietrich, Inc. on the applicability of GDPR to the professional communications industry. It was a fascinating way to discuss some of the key points of GDPR in the context of one industry/profession. Some [...]

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Innovation in Operationalizing Compliance: Part II

I am in the middle of a three-part series on how to more fully operationalize your compliance program. I am joined in this exploration by Ben Locwin. Yesterday, we considered how we how embedding compliance as a key component to the business equation of operationalizing compliance. Today we discuss why prevention is a better solution [...]

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Compliance into the Weeds-Episode 79, Starbucks and Compliance

In this episode, Matt Kelly and I go into the weeds to consider the recent racial incident at Starbucks store in Philadelphia where two African-American males were arrested for criminal trespass while waiting for a third colleague to join them for a business meeting. They had not purchased any products but were not engaging any [...]

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Innovation in Operationalizing Compliance: Part I

Over this three-part series, I will be visiting with Ben Locwin on how to more fully operationalize your compliance program. In Part I, we consider how embedding compliance as a key component of the business equation and the role of forecasting can aide in operationalizing compliance.  The Benefits of Embedding Compliance It all begins with [...]

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Innovation in Compliance Episode 6: Understanding the Fraud Pentagon with Jonathan Marks

Jonathan Marks is a leading fraud expert. He’s helped companies across multiple markets uncover fraud. Jonathan has innovated compliance by creating the Fraud Pentagon. His innovation builds upon work that was done years ago, the fraud triangle. Jonathan takes it to new levels that are in line with today’s sophisticated, technology-saturated world. Today, he and [...]

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CCO Leadership in an Age of Dynamism

One of the most constant things about the compliance profession is its dynamism. Compliance programs are not static and the compliance profession is not static. Today’s cutting edge in compliance will be tomorrow’s best practice which will be next month’s standard expectation. While this drives those who focus on the law around compliance batty, properly [...]

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FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure

In this episode of the FCPA Compliance Report, I visit with Laura Perkins, a partner at Hughes Hubbard & Reed. Perkins formerly worked with the Department of Justice, FCPA Unit, departing in September 2017. We discuss the decision of self-disclosure of a potential FCPA violation to the Justice Department. Some of the highlights include: What [...]

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Starbucks and Lessons for the Compliance Practitioner in Risk Management

There is not much more iconic in the US than Starbucks. As such they present some very visible and public lessons learned for the compliance practitioner. Recently Starbucks generated extremely negative news for having Philadelphia police arrest two persons who were waiting for a third person for a meeting. I want to use this most [...]

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This Week in FCPA-Episode 99, the banks are still behaving badly edition

With Wells Fargo having been fined $1 billion for behaving badly, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Wells Fargo has been fined $1 billion for variety of alleged misdeeds. Emily Flitter and Glenn Thrush report in the New York Times. Michael Held, general [...]

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Farewell to Sammartino: The Continued Unraveling of PDVSA Corruption

Bruno Sammartino died this week. Perhaps not as well known to most people, if you were a pro wrestling fan in the 60s and 70s you certainly had heard of Sammartino. According to his New York Times (NYT) obituary he was “an Italian immigrant who was heavyweight champion of the World Wide Wrestling Federation for [...]

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Everything Compliance-Episode 27, the Zuckerberg and Cohen Edition

This week the gang goes for more of a roundtable Q&A with a couple of topics. We first consider the testimony of Facebook CEO Mark Zuckerberg before Congress and his company’s imbroglio with Cambridge Analytica and then the search warrant issued to Michael Cohen. Stayed tuned to the end for rants in this edition. Matt [...]

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Farewell to Barbara Bush: The Role of a Compliance Committee Chair – Part II

Today I conclude my two-part series on the role of a Compliance Committee Chair. However, first I wanted to honor Barbara Bush, who died Monday. She was as beloved a First Lady as America has seen, certainly in my lifetime. In Houston, she was a near mythic figure for her generosity, love and commitment to [...]

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Compliance into the Weeds-Episode 78, an episode about Weed

In this episode, Matt Kelly and I go meta as we go into the weeds about Weed, in the context of the recent announcement by the administration that it would not prosecute persons or producers in states where marijuana sales are legal. In exchange for this concession, Colorado Senator Corey Gardner says he will lift [...]

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Farewell to Hall Greer: The Role of a Compliance Committee Chair – Part I

The National Basketball Association (NBA) playoffs have begun and there is some great hoop action going on for the next 37 days. It was in this context that I was saddened to read about the death of Hal Greer. Greer was an eight-time all-star for the Syracuse Nationals and later Philadelphia Seventy-Sixers. He was a [...]

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Innovation in Compliance Episode 5: The Future of Disrupting Risk with Dan Torpey

  Dan Torpey is a forensic accountant CPA and former auditor with over 30 years of public accounting experience. He’s a partner at Ernst & Young and the US leader of EY’s Investigation and Compliance services. With all those credentials, it should be no surprise that Dan is innovating in ways that will ripple through [...]

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Leadership Lessons from James Polk – Mind the Details but Don’t Take Your Eyes off the Goal

I continue my look at US Presidents for their leadership during their presidencies. Today, I consider James K. Polk, who was America’s 11thPresident. While only serving one-term, his presidency was certainly momentous. It provided one international war (albeit hemispheric); one near war and two major changes in economic policy. It also provided several lessons for [...]

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FCPA Compliance Report-Episode 379, Steve Durham on $83MM SEC Whistleblower Award

In March the SEC made its biggest-ever whistleblower award. It gave one person more than $33 million and in the same case split nearly $50 million between two others. The previous high for an SEC award to a single whistleblower was $30 million in 2014. All three whistleblowers were represented by the law firm of [...]

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Nights in White Satin – The Continued Pain at Wells Fargo

The Moody Blues were inducted into the Rock and Roll Hall of Fame this weekend. Ann Wilson of Heart introduced the band for their award and jam session. The band has been eligible for the Rock and Roll Hall of Fame since its inception in 1990 yet for reasons not clear they were not nominated [...]

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This Week in FCPA-Episode 98, the Red Sox are back edition

With the Red Sox leading the AL with a 10-2 start and back to brawling with the NY Yankees, Jay Rosen and myself take a look at some of the top compliance stories over the past week. Is there a new health care focus coming in FCPA enforcement actions? Joseph Spinelli and Lisa Murtha explore [...]

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Operationalizing compliance through tailored compliance training

This week I have been exploring how you can more fully operationalize your compliance program. I have considered this in the context of third-parties, forecasting and the risk management process and through the use of a root cause analysis. Today, I want to conclude this week’s blog posts with a post on operationalizing compliance through [...]

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RT @NDDCEL: Ethics training is broken. Can #storytelling fix it? https://t.co/jSyvLL7HaT https://t.co/bWjHc5zQpV 4 weeks 15 hours ago
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RT @sh_oldenberg: To Understand Complexity, Use 7 Dimensions of Ethical Thinking https://t.co/BAKgEWtIpk https://t.co/5LuaqJIiXc 2 months 1 week ago
RT @ComplianceXprts: 7 Things Every SME Exporter Needs To Know About Protecting Their Brand https://t.co/fpfGOQJQDw https://t.co/Z0VibE2IsB 2 months 2 weeks ago
RT @ComplianceXprts: Exporters Guide To Managing Compliance - Download our free ebook now!https://t.co/ypw6RwMrVE https://t.co/2NT9xereA7 2 months 2 weeks ago
RT @mikevolkov20: Episode 14 - What Every Compliance Officer Needs to Know About Data Privacy and the EU's GDPR - Corruption, Crime &… https://t.co/iZMjIPsBhs 3 months 3 weeks ago
RT @ComplianceXprts: What You Need To Know About Auditing And Risk Management In The Transport Industry https://t.co/IuMnS7mtgd 4 months 5 days ago
RT @EthicalSystems: Our 2017 End of Year Letter from @JonHaidt and @azishf https://t.co/ukjVe2Lqti "This is the time for the business… https://t.co/jUSNcY4gco 4 months 1 week ago
RT @ComplianceXprts: Inspection of Facilities and Sporting Venues - Due Diligence https://t.co/uKa3rYTJX0 https://t.co/EBXi6aBsW5 4 months 1 week ago
RT @ComplianceXprts: 14 Essentials For Your Compliance Management System https://t.co/FcQa8nRGWm https://t.co/Ru1oVnJelN 4 months 3 weeks ago