This Week in FCPA-Episode 44
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 Mars 201742min
Day 13 of One Month to Operationalizing Your Compliance Program
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 Mars 201712min
Day 12 of One Month to Operationalization of Your Compliance Program
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 Mars 201713min
Everything Compliance-Episode 8
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 Mars 201728min
Day 11 of One Month to Operationalization of Your Compliance Program
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 Mars 201712min
Compliance into the Weeds-Episode 32
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 Mars 201731min
Day 10 of One Month to Operationalizing Your Compliance Program
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 Mars 201712min
Day 9 of One Month to Operationalizing Your Compliance Program
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 Mars 201712min
