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Giving away my old age, we all loved the 1960s Batman series starring Adam West. Thanks to the Batman show we were given a long list of words to underscore Batman and Robin’s slugfests with the weekly villain (e.g. Penguin, The Riddler and the Joker). See the list
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Happy Holidays to Everyone. I wish you and your loved ones all the best for the holiday season. Corruption, Crime & Compliance will resume in January 2015. Thank you for all your support.
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The OECD has been at the forefront of the global battle against corruption. Its recent report, Foreign Bribery Report (available here) the OECD provided important insights into the occurrence of foreign bribery. The report highlighted many important issues, some of which I address below, but make no mistake the global
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I have very little patience for a corporate board that fails to do its job. A board usually consists of talented, successful and experienced professionals. They have seen good and bad business practices in their days. Board members are paid well and are not forced to agree to serve. I
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We all like to make things more complex or difficult than they need to be. Consider that a life lesson that we can share with our children, assuming they are even listening to us these days. Compliance is a field that is easy to make overly-complex. The trick is
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Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than focusing on larger risks like multi-million dollar contracts with foreign governments. I have
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Corporate boards and senior management like to focus on business. They love the numbers, the strategy and the success of a business operation. They have a passion for it and that is why they are sitting on board or managing a global company. They do not like to talk as
Events
Webinar: Tuesday, January 6, 2015, 12 Noon ESTFCPA Enforcement Year in Review Sign Up HereWebinar: Tuesday, January 13, 2015, 12 Noon ESTAML/Sanctions Enforcement Year in ReviewSign Up HereFederal prosecutors continued to aggressively enforce FCPA and AML/Sanctions in 2014. While FCPA enforcement did not resolve some of the more
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We always hear (and talk about) the rise in the compliance profession. Yes, there is increased demand for CCOs and compliance officers. More lawyers are transitioning into the compliance profession. Out in the real world, however, there are CCOs who are under the gun – they are being asked to do
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We all have heard the problem: Employees want to report their concerns directly to their immediate supervisors (unless the problem relates to the immediate supervisor); Mid-level managers complain that they do not know how to handle employee concerns. Thus, we have reached the fundamental disconnect in the corporate gestalt.
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Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues. This focus on corruption reflects the reality of enforcement. But when it comes
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A Chief Compliance Officer has a direct responsibility to promote the company’s business. That sounds like a controversial statement but it is not. Every officer and employee of a company has that responsibility. A CCO has a job – to design and implement an effective ethics and compliance program to