Blog

Blog

Defining "Tone at the Top"
May 14 2009

“We'll post the second in our cost-effective compliance series tomorrow, --addressing how anti-bribery compliance can be made relevant to managers in the field. But first, I wanted to post the best description of “tone at the top” that I’ve heard to...

Cost-Effective Compliance Strategies:  Management Message
May 12 2009

“Compliance is expensive. The need for external lawyers, auditors, forensic accountants and in-house compliance teams is being questioned as budgets are cut in other areas. Department of Justice representatives have acknowledged that companies are...

When the Nigerians ask it of us.
May 6 2009

“The International Bar Association held its annual anti-corruption conference in Prague last week. Late on the final day of the conference, there was a panel devoted to facilitating payments, particularly with respect to corrupt customs officials....

"An Enforcement Rich Environment"
May 1 2009

“Former U.S. Attorney General John D. Ashcroft was the featured speaker at ACI’s FCPA and International Anti-Corruption for the Pharmaceutical and Medical Device Industries conference in New York yesterday.  Although Mr. Ashcroft’s presentation...

Due Diligence: Centralized or Local Review?
April 28 2009

“In the important -- if not very glamorous -- world of due diligence, there are still some unsettled issues.   Although we often hear debates about "whether, when and what", we rarely hear anyone ask where.   Nancy Etzwiler of 3M's Office of General...

Earth Day
April 23 2009

“Today is Earth Day and it doesn’t take much imagination to follow the trail from a lot of environmental destruction back to bribery.
 
Indonesia is facing terrible deforestation.   Western multinationals, sensitive to the campaigns of...

Training:   When Americans are “International Consultants”
April 22 2009

“We asked in-house counsel and compliance officers to provide examples of issues that arose during in-person training that might not have been uncovered through any other form of training.  Most of the examples involved very specific questions about...

“If that is in your law, please fix it.”
April 18 2009

“Four of the nine commissioners from Thailand’s National Anti-Corruption Commission spent this week in Washington describing their anti-corruption efforts and learning more about the American model. I had the opportunity to meet with them informally...

Training the Ethical Audience
April 16 2009

“Employees who believe themselves to have a strong moral compass can be hostile to the suggestion that they need compliance training. Kate Atkinson of Miller & Chevalier describes this training dilemma and offers some suggested responses.
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Training:  A European Perspective
April 14 2009

“Last week’s posting on anti-bribery training challenges generated a lot of interest. To follow-up, this week we will post a series of short pieces on training tips and challenges. We invited Jean-Pierre Méan to provide a European perspective. ...