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Some things go together. Chocolate chip cookies and milk, Hepburn and Tracy, Lewis and Martin (I know, I am showing my age, but you get the point), and many other favorite combinations. So, you get the point – in the world of anti-bribery compliance, and another in my series of
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Happiness is when what you think, what you say, and what you do are in harmony – Mahatma Gandhi Happiness is an elusive concept – for some. For others who may be more enlightened or lived for years, happiness is a feeling that can be attained by commitment, determination and awareness. My
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One of the more frustrating topics for discussion is defining business ethics. It is frustrating to see how complex and unhelpful the discussion turns when defining business ethics. I have two tests for how to deal with this issue. 1. Do you use simple terms that can be easily communicated
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Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the Prosecutors, and others. This year is not an easy choice. In my
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When the going gets tough, the tough do not necessarily get going. This is evident in the world of corporate governance, compliance, and defense against aggressive government enforcement. Corporate lobbying interests are pushing a new and dangerous agenda, one that is shortsighted and certain to create problems for chief compliance
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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about third-party due diligence. Lauren's profile is here, and she can be reached at lconnell@volkovlaw.com. Most discussions of third party due diligence begin with an explanation of indirect liability and
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As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges. Compliance is a fast moving profession. More
Events
Webinar: Anti-Corruption Enforcement and Compliance -- The Year in Review January 5, 2016, 12 noon EST Sign Up Here The past year -- 2015 -- was another eventful year in global anti-corruption enforcement. While the US Department of Justice enforcement activity slowed, the SEC and other governments increased enforcement activity. DOJ&
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You know a company’s culture is suffering when you hear the CEO or senior executives say the best way to develop a “Speak Up” culture is to just tell all the employees “we want to hear from you.” I am an advocate for simplicity but sometimes simplicity can slip
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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about self-reporting FCPA violations. Lauren's profile is here, and she can be reached at lconnell@volkovlaw.com. One of the critical questions when evaluating a potential FCPA violation is to decide whether
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If your company is big enough and has the resources to consider establishing an internal ombudsman’s function, consider yourself lucky. When compliance professionals and lawyers use the term “ombudsman,” it is important to define how the term is being used. The most effective model for an ombudsman is the
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The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU (video here), Andrew Weissmann, the head of the Fraud