FCPA Compliance Report

At its heart, every business tries to plan for its future. It is a critical aspect of any management of any organization, non-profits, privately owned for profits and, of course, publicly traded compa...

7 Mars 201713min

In this Part III to a three part podcast series, I visit with noted risk management expert, Ben Locwin on risk-based monitoring as a adjunct to forecasting and risk assessments. We discuss how to acco...

7 Mars 201720min

Analysis and Remediation of Underlying Misconduct Root Cause Analysis – What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified? Who in the company...

6 Mars 201712min

Jay Rosen and I dedicate the entire episode to the FUBAR surrounding the Oscar ceremony where the Best Picture award was given to the wrong picture. We consider the control failures around the inciden...

3 Mars 201725min

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section in February. The document is an 11-part ...

3 Mars 201713min

The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is...

2 Mars 201711min

One event which promises to be most excellent is the upcoming Third-Party Risk Management & Oversight Summit, on March 20 & 21 at the Princeton Club in New York City. I will be attending and speaking ...

2 Mars 201717min

Last month, the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of Corporate Compliance Programs” (Evaluation), on the Fraud Section website. The document is an 11-p...

1 Mars 201710min