Compliance Tip of the Day: Rethinking Corporate AI Governance Through Design Intelligence
Podcast - “I Lied Like a Dog!”
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Sittenfeld v. United States – Campaign Contributions as Crimes?
Podcast - Persistence and Determination
Daily Compliance News: July 14, 2025, The Secret Business Sauce-Reading Edition
Adventures in Compliance: The Novels – The Hound of the Baskervilles: Uncovering Compliance – Lessons from The Hound of the Baskervilles
FCPA Compliance Report: Ethical Challenges in AI, Data Protection, and Sports with Andre Paris
Daily Compliance News: July 11, 2025, The What is a COI Edition
Because that's what heroes Do: Deep Space 9 – Episode 29: Character Dynamics and Ethical Tensions in When it Rains
Treating Compliance Like an Asset
Daily Compliance News: July 9, 2025, The TACO Don Caves Again Edition
Daily Compliance News: July 8, 2025, The Learning on the Job Edition
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
The Dark Patterns Behind Corporate Scandals
Daily Compliance News: June 26, 2025, The? Matt Galvin Honored Edition
Regulatory Ramblings: Episode 72 - Cultural Roots, Belonging, and the Fear of Change: What’s Next for Inclusion?
SBR-Authors Podcast: Unconditional Values in Leadership and Compliance with Andy Crocker
On June 9, 2025, the U.S. DOJ issued new FCPA enforcement guidelines to the global anti-corruption community, effectively ending the recent enforcement pause. This newly released enforcement framework signals a focused and...more
This essay traces the origin and development of the first dedicated law school course on corporate compliance and ethics programs in the United States. Responding to legal and practice developments over the last two decades,...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
In a recent episode of the FCPA Compliance Podcast, we discussed the 2024 Ethisphere Ethical Culture Report, “Closing the Speak Up Gap,” with Erica Salmon Byrne. As an expert in ethical culture and a familiar voice to our...more
We continue our exploration of aspects of corporate culture. Today, we turn to the dark side by reviewing some of the characteristics of a toxic corporate culture. An article in the MIT Sloan Management Review provided some...more
In the FCPA Compliance and Ethics Blog this week, I will explore corporate culture from various angles. Since at least October 2021, the Department of Justice (DOJ) has made corporate culture part of its review for any...more
The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...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
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
The Justice Department has resumed FCPA enforcement with a bang. The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a...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
On October 28, 2021, Deputy Attorney General Lisa Monaco addressed the ABA’s National Institute on White Collar Crime, in which she made clear that monitorships are back on the menu as a means of ensuring corporate...more
Ethics and compliance professionals believe in their mission – if they did not, they would not be in the field. E&C professionals believe in the power of positive thinking, ethical conduct, and in the overall ability of an...more
On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more
The Biden Administration has a lot on its plate – that is obvious. Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....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
DOJ and the SEC have provided unprecedented compliance guidance and information. DOJ has established itself as the preeminent leader in advancing ethics and compliance programs, best practices and innovations. No agency or...more
We are on the final countdown to Number 500. Next week, on Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more
I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
Compliance Convergence. In 2019 there were three significant releases of information by the federal government which directly impacted compliance professionals. Two came from the Department of Justice (DOJ) and one came from...more
In the 2017 FCPA Corporate Enforcement Policy, the Department of Justice (DOJ) listed the following factors relating to a corporate compliance function, that it would consider as indicia of an effective compliance and ethics...more