John Bell Hood and the Measurement of Conduct Risk

History might be told a bit differently if risk conduct analyses were common practice. These days, there's as much need as ever to address conduct risk, setting policies, incentive structures and enforcement practices in our organizations that reward good conduct and penalize acting contrary to the companies' values and regulatory standards.


No Sex Please, We’re British: More from GSK in China

The GSK China scandal came to light through a sex tape, and the anonymous whistleblower who leaked the tape also presented allegations of bribery. GSK's own investigation into the matter has failed to net anything of substance, but the Chinese government has turned up a great deal of evidence pointing to massive systemic bribery.


In Due Diligence and World Cup Bids: Follow the Money

In the past month, we've heard plenty of allegations of corruption associated with the Brazil World Cup, but there's as much or more controversy surrounding the forthcoming events in Qatar. Tom Fox suggests that when there's a question of corruption, just follow the money. And in this case, it's flying in all sorts of questionable directions.

old west gunman

Coolness in Being the Bad Guy? Eli Wallach and GSK

GlaxoSmithKline has gotten plenty of negative attention lately for allegations of widespread corruption in its China operations, accusations that may cause irreparable harm to the pharma giant. Regulatory bodies far and wide are jockeying for position to charge GSK, sending the message that corruption will not be tolerated. Compliance practitioners, take note!

man with idea

Common Sense in the Definition of “Instrumentality” Under the FCPA

An opinion released Friday by the Court of Appeals offers some much needed clarity on just what organizations are considered “instrumentalities” under the Foreign Corrupt Practices Act. Here, Tom Fox explores this decision, as well as early amendments to the FCPA supporting the Court’s findings and methods for establishing instrumentaility. The findings seem to be based entirely ...

FDR monument

Hitting the Ground Running – Your First 100 Days as a New CCO

The changes Presidents bring to pass in their first 100 days in office have long been the measure of their success early on. Like our commanders in chief, our CCOs should aim to hit the ground running, quickly establishing themselves as champions of ethics and compliance. The first orders of business for new CCOs: use all resources ...

Josh Withers /

The Red-Headed Stranger and the Arachnys Open Data Compass

I thought about Willie Nelson when I came across a recent release by the UK company Arachnys Information Services Ltd (Arachnys), entitled Open Data Compass, about their tool designed to help businesses identify "information blind spots and evaluate online access to corporate, litigation and news records from emerging markets."