FCPA Compliance Report

In this episode, Jay and I have a wide-ranging discussion on the intersection of culture and ethics. We discuss:  German authorities raid at VW investigation counsel, Jones Day, offices in Germany a...

17 Maalis 201742min

Another way to operationalize compliance is to have oversight moved out into regions. Such an approach can more effectively ensure employee and third party compliance with your Code of Conduct through...

17 Maalis 201712min

The operationalization of your compliance programs means how deeply is compliance integrated into the function of your company. Today, I want to consider another way to operationalize compliance throu...

16 Maalis 201713min

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Matt Kelly and Mike Volkov provide next insight. Nex...

16 Maalis 201728min

Today I want to explore in some detail the first Objective in the COSO 2013 Framework-the Control Environment as a path to operationalize your compliance program. This Objective lays out five steps yo...

15 Maalis 201712min

In this episode, Matt Kelly and I take a deep dive into a dramatic 48 hours in the life of the FCPA last week, which portends the trend of continued FCPA enforcement. It included the announcement by K...

15 Maalis 201731min

Under the Prong entitled “Policies and Procedures” subtexted Operational Integration, the Evaluation states:  Payment Systems – How was the misconduct in question funded (e.g., purchase orders, emplo...

14 Maalis 201712min

If there is one over-riding theme from the recently released Evaluation of Corporate Compliance programs it is that a corporate compliance program must be operationalized. Indeed that is the theme of ...

13 Maalis 201712min