Day 3 of 31 Days to a More Effective Compliance Program
This requirement is more than simply the ubiquitous ‘tone-at-the-top’ as it focuses on the conduct of senior management. The Justice Department wants to see a company’s senior leadership actually doin...
3 Jan 201812min
Day 2 of 31 Days to a More Effective Compliance Program
Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an import...
2 Jan 201812min
FCPA Compliance Report-Episode 364
In this episode, I visit with SCCE incoming President Gerry Zack about his new role with the organization. Learn more about your ad choices. Visit megaphone.fm/adchoices
2 Jan 201819min
This Week in FCPA-Episode 82
Jay and I take things in a different direction this week. We take the top five podcasts from 2017 and each of us, gives a highlight from that episode to highlight some of the key compliance issues fro...
31 Dec 201739min
Day 1 of 31 Days to a More Effective Compliance Program
Over the next 31 days, I will be exploring the best way to more fully operationalize a compliance program using the DOJ resources. Join me as we engage in 31 days to a more effective compliance progra...
31 Dec 201715min
Day 21 of One Month to Better Written Standards
This entry provides a wrap up on written standards, with a discussion on policies on cybersecurity. Regarding policies on cybersecurity, it has become so critical for corporation that the CCO and many...
31 Dec 20179min
Day 20 of One Month to Better Written Standards
The next area for policies is extortion payments, which are completely exempted out of the FCPA. Extortion payments are made for any action which threatens or demands payment for life, liberty, or hea...
30 Dec 201710min
Day 19 of One Month to Better Written Standards
As every compliance practitioner is well aware, third parties still present the highest risk under the Foreign Corrupt Practices Act. The Department of Justice Evaluation of Corporate Compliance Progr...
29 Dec 201711min
