FCPA Compliance Report

The next step in the five-step process is the Questionnaire. The term ‘questionnaire’ is mentioned several times in the 2012 FCPA Guidance. It is generally recognized as one of the tools that a compan...

5 Huhti 201712min

In this episode Matt Kelly and I take a deep dive into the recent kerfuffle involving United Airlines and its policy which prevented to teenaged girls from boarding a flight wearing leggings. Was Unit...

5 Huhti 201720min

The Evaluation, in Prong 10, Third Part Management asks, “What was the business rationale for the use of the third party in question?” This question is one of the most basic tools to operationalize yo...

4 Huhti 201711min

In this episode I visit with John Hanson (AKA 'the Fraud Guy') who is also the founder of the International Association of Independent Corporate Monitors (IAICM). He discusses why he founded the group...

4 Huhti 201728min

Day 1- The Third-Party Risk Management Process This month, I will consider the risk management of third parties in an operationalized compliance program. As every compliance practitioner is well awar...

3 Huhti 201714min

I conclude my One Month to Operationalizing your Compliance Program series by discussing how you can put your compliance program at the center of corporate strategy. An article in the Harvard Business...

31 Maalis 201713min

Show Notes for Episode 46, for the week ending March 31, the On the Road to Prague Edition  In this episode, Jay and I have a wide-ranging discussion on operationalizing compliance through business p...

31 Maalis 201728min

The Evaluation of Corporate Compliance Programs, Prong 6, Incentives and Disciplinary Measures states:  Incentive System – How has the company incentivized compliance and ethical behavior? How has th...

30 Maalis 201713min