Creating Trust to Affect Compliance Change

One of the greatest challenges corporate compliance practitioners face is securing buy-in from staff on compliance objectives, as well as their participation in meeting these goals. To do that, the compliance function can't be viewed as "The Land of No," but as a valued partner in the success and profitability of the business. So where do we ...


Highway 61 and IRS Involvement in FCPA Enforcement

If you need a reason to bolster your monitoring efforts, you may find the recent FCPA enforcement action against Vicente Eduardo Garcia to be quite instructive. One noteworthy feature of this investigation was the involvement of the IRS’s Criminal Investigation unit, the lesser-discussed of the DOJ’s two investigative bodies, called in to comb through mountains of data and ...


Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Just as the football season kicks off, Baylor University is embroiled in scandal. One of the football team's prized recruits was recently convicted of sexual assault. Part of the trouble here is that the university doesn't seem to have done its homework on the athlete. When the story of his conviction broke, the finger pointing began. ...


Amazon’s Culture, the Greatest Brawl in Baseball and Compliance

Amazon has long been known for its dynamic culture, but it's becoming increasingly evident that the company's culture has a seedy underbelly. Workers are treated miserably, and programs presumably designed to improve employees' experience are being used to punish them and pit one team member against another. What does this mean for the compliance practitioner? Read on.


Georgia On My Mind – How Does Compliance Enhance Shareholder Value?

What does the compliance function do to increase shareholder value? It's a question you've no doubt heard before, in some form or another. Tom Fox argues that no company with strong internal controls is run more poorly because of them. No -- in fact, stakeholders are necessarily better off when the company is kept on the ...

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Social Media Week Part II – Sharing in the Compliance Function

According to social strategist and author Bryan Kramer, there are five types of people who share content on social media. Each type can be of value to an organization as it integrates social media into its compliance program. Considering the merits of each type of "sharer" can also be helpful in determining which employees can best help elevate ...

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Social Media Week Part I – Using Social Media In Your Compliance Program

There is a place for social media in your compliance program. Using sites such as Facebook and Twitter to broadcast your company's commitment to compliance can be effective, but apps specific to FCPA and anti-bribery/anti-corruption compliance are also worth exploring. Tom Fox opens the discussion about how to integrate social media into your compliance program.


The Third Man and the Authority of Chief Compliance Officers

Whatever your company's stance on to whom the Corporate Compliance Officer should report, what's not in question is that the CCO must be able to act from a place of authority. Strip the CCO of his power and influence, and your compliance program is bound to fail. Tom Fox walks us through five key indicators that a ...


Commodore Perry and Integrating Compliance into the Fabric of Your Company

When the compliance function isn't fully integrated into a company's DNA, there's bound to be a clash of priorities. In these cases, it's often financial objectives that take precedence. As we all know by now -- and pardon the throwback to Compliance 101 -- that simply won't do. Paper compliance programs don't cut the mustard. ...

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Channeling John Steed in Your Tone in the Middle

A strong tone at the top is essential to maintaining a culture of compliance. Equally as important, however, is tone in the middle. If your middle managers don't understand or aren't on board with a commitment to operate with integrity and in compliance, the message they project to their teams won't likely be reflective of the organization's ...