FCPA Compliance Report

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

In this episode, Matt Kelly and I take a deep dive into the weeds of the soon-to-be-released the House Financial Services Committee, the Financial Choice 2.0 Act. We consider some of the ideas in the ...

3 Touko 201724min

BNY Mellon Up until the summer of 2015, hiring practices under the FCPA were not been given much thought or widely discussed. However that began to change in the summer of 2015 when the SEC announce...

2 Touko 201712min

In this podcast, Marc Bohn and James Tillen from the firm of Miller & Chevalier, discuss their recent publication entitled, "Evaluating FCPA Pilot Program: Declinations on the Rise" where they review ...

2 Touko 201729min

Day 1-  The Role of Human Resources in Operationalizing Compliance This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long ad...

1 Touko 201712min