One does not have to look very far in the business world to come across the phrase “Know Your Customer.” But how much more should a company do in regards to its customers?
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In FCPA Enforcement Sometimes Truth is Stranger than Fiction – The Cilnis Complaint
May 14, 2013
I often marvel at some of the stories which come up in the context of Foreign Corrupt Practices Act (FCPA) investigations and enforcement. If you made up some of the things which are reported, I fear that people might find you simply crazy.
FCPA Prosecutions Against Individuals? Check Out April
May 1, 2013
In the month of April, the US enforcement agencies certainly seemed to be answering the questions about bringing FCPA criminal charges and civil complaints against individuals…
Using Bribery and Corruption to Steal Business – A Thyestean Feast?
April 24, 2013
Not much beats the ancient Greek House of Atreus for dramatic gore: infanticide, patricide, fratricide, filicide, matricide, cannibalism, incest and about every other horror which can befall one family…
Interview with Maurice Gilbert — Founder of Conselium and Corporate Compliance Insights
April 11, 2013
Q&A: Tom Fox and CCI Founder Maurice Gillbert talk about finding top talent for compliance jobs in the U.S. and around the globe — as well as the importance of educating management about having an ethical and compliant environment.
M*A*S*H and Triage in Your FCPA Investigation Protocol
April 4, 2013
Having a robust triage system is an important way that a company can separate the wheat from the chaff and bring the right number of resources to bear on a problem.
What is Risk? Compliance Lessons from the Senate Hearing On the Whale
March 22, 2013
One of the risks that require management is losses around trading. This was on painful display last week in the investigations hearings into the JP Morgan trading losses known as the “London Whale.”
Compliance Programs: What’s the Gold Standard?
March 14, 2013
What is the gold standard for scientific minds? You might not do better than Albert Einstein who was born on this date in 1879.
How to Introduce Change into Your FCPA Compliance Program (Without Blowing It Up)
February 26, 2013
In making a large change, most compliance practitioners think of bringing it all to a company in one fell swoop. This is usually based on a Board of Directors or senior management directive to ‘get it done’.
Manti Te’o and a Second Set of Eyes
February 19, 2013
The Manti Te’o story provides some significant lessons for the compliance practitioner. Putting a ‘second set of eyes’ on any process, including compliance is the only way to validate the process.
