Day 12 of 30 Days to a Better Compliance Program
You should work to create a culture of data in your compliance program. This comes from an understanding that data is a product, which you can consume internally in the compliance function. Your data ...
13 Jan 20179min
Day 11 of 30 Days to a Better Compliance Program
You should employ a 6-step process to revising your Code of Conduct. Get buy-in from decision makers at the highest level of the company Your company’s highest level must give the mandate for a re...
12 Jan 201711min
FCPA Compliance Report-Episode 299, Philip Urofsky
In this episode, I visit with Sherman & Sterling partner Phillip Urofsky who leads a team which produced the the 2017 FCPA Digest, one of the top annual compendium of annual FCPA reviews of the prior ...
12 Jan 201735min
Compliance into the Weeds-Episode 24
In this episode Matt Kelly and myself take a deep dive into the compliance weeds by looking at a paper written by then SEC General Counsel James Doty (later head of the PCAOB) in 2007 where he propose...
11 Jan 201727min
Day 10 of 30 Days to a Better Compliance Program
A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps, most commonly, inadequate due diligence can allow a course of b...
11 Jan 201714min
Day 9 of 30 Days to a Better Compliance Program
No area has become more challenging in compliance than continuous improvement. The FCPA Guidance specifies that “a good compliance program should constantly evolve. A company’s business changes over t...
10 Jan 201715min
FCPA Compliance Report-Episode 298, Leona Lewis
In this episode I visit with Leona Lewis, the founder and host of the podcast Masters of Disaster. She reflects on her experiences over the past 18 months of podcasting; what she learned, what surpris...
10 Jan 201724min
Day 8 of 30 Days to a Better Compliance Program
The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a...
9 Jan 201712min
