2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Sittenfeld v. United States – Campaign Contributions as Crimes?
Daily Compliance News: July 14, 2025, The Secret Business Sauce-Reading Edition
10 For 10: Top Compliance Stories For the Week Ending, July 12, 2025
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
Compliance Tip of the Day: New FCPA Enforcement Memo - What Does it Say?
Daily Compliance News: May 30, 2025, The Leissner Sentenced Edition
Daily Compliance News: May 28, 2025, The Moron Premium Edition
Daily Compliance News: May 27, 2025, The Boeing Off the Hook Edition
Daily Compliance News: May 22, 2025, The Trump and Dump Edition
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Daily Compliance News: April 8, 2025, The End of Monitors Edition
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
2 Gurus Talk Compliance: Episode 48 – The March Madness Edition
Cross-jurisdiction cooperation in the fight against international corruption and bribery is intensifying. The UK’s Serious Fraud Office (SFO), France’s National Financial Prosecutor’s Office (PNF), and Switzerland’s Office of...more
An amendment to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA) in April 2024 has created a new criminal offense relating to the failure by members of the private sector or state-owned entities...more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Basic Compliance & Ethics Academy overview - Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style...more
Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more
Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more
CEP Magazine – April 2022 - As usual, Joe Murphy wrote an excellent column this month dealing with risk assessments. We must be leading parallel lives, because I also had an idea about risk assessments I wanted to share....more
CEP Magazine (March 2022) - In November 2021, the Organisation for Economic Co-operation and Development (OECD) issued a significant update to its guidance on combating bribery of foreign public officials, replacing its...more
Discover how to set and accomplish your ESG goals - Environment, Social, and Governance (ESG) is no longer an isolated function within a company, nor is it an issue only for publicly traded companies. It’s front and...more
Are you looking to better... - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more
As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more
Recently, three of Australia's four largest banks have self-reported breaches of anti-money laundering and counter-terrorism financing laws. Commonwealth Bank of Australia in 2018 admitted fault and agreed to pay a civil...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more
The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post. Putting those concerns aside, there are some important lessons learned and observations that...more
The Foreign Corrupt Practices Act (FCPA) world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena....more
Companies are hyper-focused on third-party risks, especially when it comes to anti-corruption risks. And for good reason – a large percentage of FCPA enforcement actions involve illegal use of third parties to carry out...more
In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more
There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more
Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more