Increase the Number of Women on Corporate Boards

Corporate boards need more women.  That is a simple statement, backed by research and evidence that… [continue]

Increase the Number of Women on Corporate Boards Increase the Number of Women on Corporate Boards

Three Blind Mice and the HP FCPA Settlement

The HP FCPA settlement was not your run-of-the-mill enforcement action.  The blogosphere has been filled… [continue]

Three Blind Mice and the HP FCPA Settlement Three Blind Mice and the HP FCPA Settlement

The Apple Monitorship: Airing Dirty Laundry

I am married to a lovely Sicilian-born woman.  One thing her family has taught me – the value of family… [continue]

The Apple Monitorship: Airing Dirty Laundry The Apple Monitorship: Airing Dirty Laundry

Webinar: Managing Your Anti-Corruption Policies and Procedures

Webinar: April 29, 2014, 12 Noon EST Managing Your Anti-Corruption Compliance Policies and Procedures  Sign… [continue]

Webinar: Managing Your Anti-Corruption Policies and Procedures Webinar: Managing Your Anti-Corruption Policies and Procedures

Sifting Through the Ukraine Economic Sanctions

It is odd how a foreign crisis can have a dramatic impact on the world of ethics and compliance.  Foreign… [continue]

Sifting Through the Ukraine Economic Sanctions Sifting Through the Ukraine Economic Sanctions
Latest Posts

Increase the Number of Women on Corporate Boards

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Corporate boards need more women.  That is a simple statement, backed by research and evidence that corporate boards with more women are more profitable.  I have written about that in the past. A recent study found another benefit from increasing the number of women on a corporate board – women … Continue Reading…

Three Blind Mice and the HP FCPA Settlement

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The HP FCPA settlement was not your run-of-the-mill enforcement action.  The blogosphere has been filled with different analyses and interpretations.  Client alerts have been taking shots at coming up with original ideas and takeaways. HP is an unusual settlement for the following reasons: 1.  The Three-Part settlement is highly unusual … Continue Reading…

The Apple Monitorship: Airing Dirty Laundry

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I am married to a lovely Sicilian-born woman.  One thing her family has taught me – the value of family loyalty and love. That same principle does not apply when it comes to the relationship between the Apple Monitor and Apple.  In a rare public filing, the external monitor for … Continue Reading…

Webinar: Managing Your Anti-Corruption Policies and Procedures

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Webinar: April 29, 2014, 12 Noon EST Managing Your Anti-Corruption Compliance Policies and Procedures  Sign Up Here In response to the aggressive enforcement environment, companies have adopted robust anti-corruption policies and procedures. As always, the effectiveness of a company’s policies depends on implementation, management and monitoring of its policies. Companies … Continue Reading…

Sifting Through the Ukraine Economic Sanctions

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It is odd how a foreign crisis can have a dramatic impact on the world of ethics and compliance.  Foreign policy headaches turn into compliance nightmares when the United States becomes embroiled in foreign events. For years, under the Obama Administration, sanctions have become the weapon of choice in foreign … Continue Reading…

Mitigating Bribery Risks with Financial Controls

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Anti-corruption compliance is not as hard as it looks.  In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt compliance policies and procedures.  Compliance policies and procedures give the board, senior managers and the CCO a … Continue Reading…

AML Enforcement and Sanctions

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AML enforcement often includes sanctions violations.  The Office of Foreign Asset Control (OFAC) is responsible for regulating and enforcing the sanctions regime. OFAC has played a critical role in ramping up AML enforcement against major financial institutions.  Major enforcement actions have been built on OFAC violations. HSBC Holdings paid OFAC … Continue Reading…

A Close Look at Internal Controls

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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 companies that have weak internal controls. A company’s internal controls have to provide reasonable assurances regarding the reliability of the … Continue Reading…

To Be a Criminal, You Have to Act Like a Criminal

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Lawyers, compliance professionals and senior management at companies can be obsessive when it comes to the threat of criminal liability.  Please do not get me wrong, I am not minimizing the risk of criminal prosecution, nor I am suggesting that everyone go out and start paying bribes overseas. That being … Continue Reading…

Paper Tigers and Paper Compliance

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The FCPA Guidance is an extraordinary document filled with excellent ideas, defined safe harbors and important enforcement and compliance principles.   It is a lesson in good government, and a testament to an instructive process for government and business communications and interaction. The hypothetical scenarios and basic advice set out in … Continue Reading…