Day 27 of 30 Days to a Better Compliance Program
Employment separations can be one of the trickiest maneuvers to manage in the spectrum of the employment relationship. Even when an employee is aware layoffs are coming it can still be quite a shock w...
28 Jan 201712min
Day 26 of 30 Days to a Better Compliance Program
As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The BHP...
27 Jan 201712min
Day 25 of 30 Days to a Better Compliance Program
Many Chief Compliance Officers (CCOs) and compliance practitioners struggle with metrics to demonstrate revenue generation. Most of the time, such functions are simply viewed as non-revenue generating...
26 Jan 201713min
Day 24 of 30 Days to a Better Compliance Program
Today, I the Holy Grail of compliance –Return on Investment—for your compliance program. In a very interesting article by Paul Healy and George Serafeim entitled, “An Analysis of Firms’ Self-Reported ...
25 Jan 201711min
Day 23 of 30 Days to a Better Compliance Program
I often write about the nuts and bolts of an effective compliance program but one of the most basic things that an effective compliance program must have is a compliance department present to ask the ...
24 Jan 201712min
Day 19 of 30 Days to a Better Compliance Program
Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar ba...
20 Jan 201710min
FCPA Compliance Report-Episode 301, Jonathan Armstrong
In this episode I visit with Jonathan Armstrong about the UK portion of the Rolls-Royce global anti-corruption settlement. We discuss the UK Deferred Prosecution Agreement, how it came about, what it ...
19 Jan 201720min
Day 18 of 30 Days to a Better Compliance Program
Continuous improvement requires that you not only audit third parties but also monitor whether employees are staying with the compliance program. In addition to the language set out in the FCPA Guidan...
19 Jan 201712min
