Compliance Tip of the Day: Trust and Verify
Great Woman in Compliance: Building Strategic and Effective Risk Assessments
Compliance into the Weeds: The Dark Side of AI in Employee Training
Compliance Tip of the Day: AI Assistant for Compliance
Sunday Book Review: August 17, 2025, The More Books from the Ethicsverse Library Edition
Compliance Tip of the Day: How a CFO Views Compliance and Risk
Data Driven Compliance – James Tillen on the Importance of Cross-Functional Collaboration in Complying with the FTPF Offense
What to Do When Leadership Doesn’t Take Compliance Seriously
Compliance Tip of the Day: Finance Models for Compliance
Compliance Tip of the Day - Extending Compliance Value Across Your Organization
Adventures in Compliance: The Novels - The Valley of Fear, Sherlock Holmes’ Investigative Techniques for Today’s Challenges
Moving Beyond the Usual Helpline Data
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
Compliance Tip of the Day: AI and 3rd Party Risk Management
Compliance Tip of the Day: Strategies for Embedding Compliance into your Organization
Compliance Tip of the Day: Crowd Sourcing Risk Intelligence
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 3, Strategy
Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode I welcome back Steve Vincze back to discuss the recent corporate scandal involving executives from Astronomer. ...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...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 is the value of having a Code of Conduct? I have heard many business folks ask that question over the years. In its early days, a Code of Conduct tended to be a lawyer-written and lawyer-driven document to wave in...more
The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...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
The United States has been the global leader in the enforcement of anti-bribery and anti-corruption laws for several decades. The Foreign Corrupt Practices Act (FCPA) was enacted in the United States in 1977 in order to...more
The full agenda for ACI's 36th International Conference on the Foreign Corrupt Practices Act this December is now available. See why this event stands apart as the annual gathering for the worldwide anti-corruption...more
I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more
In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...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
The Situation: On April 30, 2019, the U.S. Department of Justice ("DOJ") released an updated version of its guidance document, "Evaluation of Corporate Compliance Programs," in an effort to "better harmonize" the document...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...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
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
In our perpetual quest for simplicity, sometimes we fail to understand the complexity of an issue. In the corporate world, if you ask board members and CEOs how they would define a compliance program ”failure,” I am sure...more
External whistleblower activity can be very costly in the auto industry. As the industry continues to develop, prevention of whistleblower claims will only grow in importance. It’s an issue that can impact every company...more
What happens when a company delivers a superior product or service which is enthusiastically embraced by the consuming public, has a contented, if not equally enthusiastic, public facing work force and the business itself...more
Today, we conclude our week long exploration of the original Star Wars trilogy, all posted in conjunction with three podcasts, subtitled May The Podcast Be With You, where we use one movie as a staring point to review Foreign...more
Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne. Testament to the fiery...more
In this blog post I continue my exploration of how you should assess your compliance internal controls using the Committee of Sponsoring Organization of the Treadway Organization (COSO), publication “Internal Controls –...more
This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more
This post continues my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adherence to the COSO 2013...more
In this episode I begin a two-part review of the 2014 FCPA year. In this episode I review some of the significant corporate enforcement actions. ...more