compliance programs

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Global Innovation for Your Compliance Program

One of the areas where the best practices for Foreign Corrupt Practices Act (FCPA) compliance programs is evolving is in the area of a less U.S.-centric approach and incorporating the diversity across the globe. Many companies are now realizing that there should not be a one-size-fits-all compliance program and that there is a treasure trove of ideas and capabilities ...

compliance programs continuous monitoring

The Face of Battle: Sir John Keegan and the Individual in Compliance

Just as you can learn and experience history by studying the individuals who participated in great events, your compliance program should be aimed at individuals to guide their ethical behavior based upon your company’s compliance regime. You should think of Sir John Keegan’s work on the individual in battle in conjunction with what your compliance program is doing to ...

The Righteous Mind: A Must Read for C&E Professionals

Last year saw the publication of an important book on behavioral ethics – Blind Spots – by Max H. Bazerman and Ann E. Tenbrunsel, and in a prior article I describe what some of the implications of this emerging field might be for compliance and ethics programs. In today’s column I want to draw attention to another […]

grammy award winning adele teaches compliance lessons

Compliance Rocks: Adele is Phat (And Teaches Compliance Lessons)

I was watching the Grammy Awards show last night and found my love for Adele Adkins thoroughly validated. She is phat. Not “f-a-t” of course but “p-h-a-t” – i.e., urban slang for very attractive or appealing. I know, I know. It’s a really bad play-on-words in light of the unfair controversy over her appearance. I […]

end of facilitation payments

The End is Nigh for Facilitation Payments – Get Ahead of the Breeze

Last summer, the University of Pennsylvania’s Journal of Business Law published an article titled “The OECD’s Call for an End to the ‘Corrosive’ Facilitation Payments and the International Focus on the Facilitation Payments Exception under the Foreign Corrupt Practices Act.” It was authored by Jon Jordan, senior investigations counsel, in the Foreign Corrupt Practices Act (FCPA) Unit of […]