Episode 379 -- Update on False Claims Act and Customs Evasion Liability
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Daily Compliance News: July 17, 2025, The COSO Yanked Edition
Podcast - Persistence and Determination
Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
Regulatory Ramblings: Episode 73 - Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
Current Regulatory, Legislative, and Litigation Developments on ADA Website Accessibility for Consumer Finance Digital Platforms — The Consumer Finance Podcast
Podcast - How Do You Define Success?
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Compliance Tip of the Day – New FCPA Enforcement Memo – What Does it Mean?
Daily Compliance News: June 17, 2025, The JBS Goes Public Edition
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more
Whether part of local customs, relationship building or ways to give thanks, gift giving and hospitality (collectively referred to here as “Hospitality”) is a sizable business, with the global market being estimated at USD839...more
I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more
In 2025, whistleblower regulations are poised for major evolution, reflecting a renewed commitment to transparency and accountability. The Ethics and Compliance Initiative (ECI) 2023 survey revealed a startling statistic:...more
I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
Some were surprised by the recent move by the Department of Justice in focusing on the importance of incentives and disincentives as an important factor in an effective ethics and compliance program. Others, however, had been...more
DOJ and the SEC each had a great year in FCPA enforcement. But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more
We are here and today I am extraordinarily honored to post my 500th Anniversary podcast. Now, I switch seats to be the guest as I am interviewed by Gregg Greenberg, the General Manager of C-Suite Radio. We take a look back at...more
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
The long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was recently announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more
Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more
The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more
The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...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
Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner, it...more
Tilman Fertitta has purchased the Houston Rockets from current owner Les Alexander for the stunning sum of $2.2 bn. The sales price breaks the National Basketball Association (NBA) record sale of $2 billion from when the...more
This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more
Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more
Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more
All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more