Managing Whistlelbowers
Culture Crafters: Building a Culture of Accountability in the Face of Disasters
FCPA Compliance Report: Accountability in Times of Crisis: A Conversation with Tom Fox and Sam Silverstein
Adventure in Compliance: The Novels - The Valley of Fear, Whistleblowers and Corporate Compliance
What to Do When Leadership Doesn’t Take Compliance Seriously
Great Women in Compliance: The Mind at Work with Lynette Buebird
Innovation in Compliance - Constructive Conversations: Insights with Nina Sunday
Sunday Book Review: August 10, 2025, The More Books from The Ethicsverse Library Edition
Creativity and Compliance: Reinventing Compliance with Creativity: The Acteon I-Care Code
Moving Beyond the Usual Helpline Data
Great Women in Compliance: LATAM Compliance Update with Alejandra Montenegro Almonte
Adventures in Compliance: The Novels - The Valley of Fear, Introduction and Compliance Lessons Learned
FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze
12 O’Clock High, a podcast on business leadership: Building Trust and Relationships: The Power of Compliance and Ethics with Jacqui Pruet
2 Gurus Talk Compliance: Episode 56 – The Grasshopper Edition
Daily Compliance News: July 31, 2025. The Forgotten Generation Edition
Daily Compliance News: July 30, 2025, The Corruption Kill Business Edition
Great Woman in Compliance: The Power of Vulnerability with Cricket Snyder
Adventures in Compliance: The Novels – The Hound of the Baskervilles: Uncovering M&A Compliance Lessons
Compliance Tip of the Day: Strategies for Embedding Compliance into your Organization
On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more
The Department of Justice (DOJ) is currently in a conundrum over its Deferred Prosecution Agreement (DPA) for the Boeing 737 Max crashes. Understanding the implications of the DOJ’s upcoming decision on whether to prosecute...more
Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
This is not your typical FCPA enforcement action Lessons Learned column. Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more
The Department of Justice (“DOJ” or the “Department”)’s signals that it is doubling down on corporate criminal enforcement, including focusing on individual accountability, deserve close attention. The updates, announced by...more
Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more
The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown. As I often repeat myself, there is no more important control than an ethical culture. When a culture veers into the unethical...more
In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
When considered in light of the Chancery Court’s decision, DOJ’s essential findings in its Boeing investigation are problematic at best. The Chancery Court’s decision outlines how Boeing’s culture of safety deteriorated into...more
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
Wells Fargo & Co. agreed to pay a total of $3 billion to resolve criminal and civil investigations by the DOJ and SEC. Wells Fargo admitted “that it took millions in wrongful fees and interest, misused customer information...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department and the SEC have launched criminal and civil accounting fraud investigations against Under Armour. The sportswear maker has been suffering a rapid revenue decline over the last few years....more
One of the biggest headaches for companies conducting business overseas still remains bribery and corruption. The grey area of what is deemed a fair gift, meal or payment against what might be constituted a bribe is a...more
Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan. With age, his lyrics resonate more and more. HERE is a nice version of Watch the River Flow in case you want to listen while reading...more
It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors. There are common factual scenarios that recur in...more
The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the...more
In January 2019, the US Attorney for the Eastern District of Michigan returned an indictment against four executives from Audi, a Volkswagen subsidiary, for their participation and direction of Audi’s emissions-cheating...more
This week I have been considering the new developments in the long-running 1Malaysia Development Berhad (1MDB) scandal. These developments include a guilty plea by a former Goldman Sachs Group Inc. (Goldman Sachs) banker in...more
Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more
Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more
As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more