FCPA Compliance Report

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 Apr 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 Mar 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 Mar 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 Mar 201713min

In this episode I visit with Brandon Essig, a former DOJ prosecutor when the Yates Memo was released. He discusses the impact of the Yates Memo inside the DOJ and the triage that prosecutors use on ca...

30 Mar 201726min

Even with a great Tone-At-the-Top and in the middle, you cannot stop. One of the greatest challenges of a compliance practitioner is how to affect the ‘tone at the bottom’. In an article in the Spring...

29 Mar 201713min

In this episode I visit with Jonathan Armstrong on his views on the new DOJ Evaluation of Corporate Compliance Programs. Armstrong provides a detailed analysis of some of the key differences between h...

29 Mar 201728min

The Evaluation of Corporate Compliance Programs makes clear, a company must have more than simply at good ‘Tone-at-the-Top’; it must move it down through the organization from senior management down t...

28 Mar 201713min