Avoiding a Bored Board
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?
So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...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
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
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
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
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
What have we learned from 2020? I think all of us have learned quite a bit in both our personal and professional lives. 2020 has stretched us as individuals and as organizations in various and unexpected ways. ...more
Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more
NAVEX Global recently released an important compliance report – 2019 Definitive Corporate Compliance Benchmarking Report. NAVEX’s report contains a number of interesting findings and brings together several current...more
This year is the 200thanniversary of the birth of Wuthering Heights’ author, Emily Brontë. While her sister Charlotte received more acclaim as an author, I found Wuthering Heights to appeal much more greatly to my dark side. ...more
Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more
One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the financial transactions of the...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
We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more
My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more
Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more
Companies with ineffective internal controls face risks of embezzlement and self-dealing by employees, bribery, export control violations and other possible legal violations. The payment of foreign bribes often occurs in...more