FCPA Compliance Report

Show Notes for Episode 47, for the week ending April 7, the Season Opener Edition In this episode, Jay and I have a wide-ranging discussion on some of the week’s top FCPA and compliance related stori...

7 Huhti 201739min

Yesterday I considered the need for due diligence in the management of third parties. Today, I want to take a deeper dive and explore the levels of due diligence. Due diligence is generally recognized...

7 Huhti 201712min

In this episode, I visit with Adelle Berger, who recently became the Chief Integrity Officer at Louis Berger. Some of the topics we discuss are: Why is her title “Chief Integrity Officer” as opposed...

6 Huhti 201725min

Most companies fully understand the need to comply with the FCPA requirements around third parties as they represent the greatest risks for an FCPA violation. However, most companies are not created o...

6 Huhti 201711min

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