Niccolo Machiavelli

Machiavelli for Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince, by Niccolò Machiavelli. Just how evil do many people view the treatise as? Consider that this book alone is responsible for bringing the word “Machiavellian” ...

investigation protocol

What is Your Board’s Investigation Protocol?

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises. However, many Boards do not have the same rigor when it comes to an investigation, which should be conducted or led by the Board itself.


To Snitch or Not to Snitch….

We know that a co-worker has taken sensitive information. Do we report this or not? Most people might want to report it but either don’t know who to speak with or have a hard time identifying whether or not this is truly something that needs to be reported.

fraud corporate integrity agreement

Your Corporate Compliance and the Corporate Integrity Agreement

Management that turns deaf ears when subordinates report false billing or illegal marketing in dealing with federal or state governments can unleash a torrent of financial and reputational harm on the company. Indeed, that scenario is just the sort of situation that can turn into a full-blown, multi-million-dollar whistleblower settlement brought by a company insider under qui tam provisions ...