FCPA Compliance Report

In this episode, Roy Snell and I discuss the following: Measuring the effectiveness of your compliance program three ways; Why Roy thinks the CO shouldn’t chair the compliance committee – but maybe...

10 Touko 201733min

In metrics laid out by former Assistant Attorney General Leslie R. Caldwell, she spoke about the need for compliance program incentives.  She posed it with the following question, “Are there mechanism...

9 Touko 201712min

In this episode I caught up with Paula Long, founder and CEO of DataGravity, Inc. at the recently concluded Collision 2017 Conference. Paula has worked in the data and information space for over 30 ye...

9 Touko 201719min

In the Department of Justice’s Evaluation of Corporate Compliance Programs, Prong 8 Incentive and Disciplinary Measures it states:  Incentive System – How has the company incentivized compliance and ...

8 Touko 201712min

Over some breakfast tacos and Mexican coffee, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss:  Uganda considers a demand side response to co...

5 Touko 201740min

Why is hiring so important under for compliance? It is because hiring is important to any company’s health and reputation. At this point, until the US Supreme Court tells us that a corporation is the ...

5 Touko 201711min

One of the theories of conventional wisdom about anti-corruption compliance is that you will never be able to reach 5% of your workforce with compliance training because they are predisposed to lie, c...

4 Touko 201713min

Today, I conclude my review of FCPA enforcement actions that involved the corporate hiring function. From these three cases I have considered, it is clear that HR must be involved in compliance and if...

3 Touko 201713min