In my interactions with the corporate compliance community, I have found a common lack of appreciation and vast under-utilization of data. When I speak with compliance education programs in both academic and professional settings, my questions on how they teach the use of data is most often met with blank stares. I believe this data … Continue reading Data Science is Here to Stay
Blog published via NAVEX Global's "You Can't Delegate Ethics" series. The Paul O'Neil at Alcoa story has always been one of my favorites to tell when it comes to senior level commitment.
In the 24 hours or so since the reporting of the U.S. President’s remark about immigrants, the reactions have been swift and strong. From the United Nations to leaders around around the world, the reported remarks have been rightly characterized as racist, degrading, reprehensible, among others. In such a time as this, silence is not … Continue reading Silence is not an option
One question I often get is my views on ISO 37001 (the “Anti-bribery management system – Requirements with guidance for use”, published October 15, 2016) and/or certification programs in general. An associated question is how does the Department of Justice (DoJ) view such certifications. On the second question, Dan Kahn, the Chief of the FCPA … Continue reading Toward Evidence-Based Programs: Thoughts on ISO 37001 and Certifications
On Tuesday, I delivered the opening keynote at Convercent’s Converge17 event, where the theme was “Ethics at the Center”. The process of preparing for this talk, and conversations after the talk, have given me a great deal of food for thought. Ethics vs. Compliance Let’s look at the dictionary definition of compliance: Compliance [noun]: (a) … Continue reading “Ethics at the Center”
Less than two weeks ago, during my workshop and roundtable in Paris and Munich, one questions came up repeatedly: “Why is the Department of Justice targeting French/German companies? Is this American legal imperialism?” The French were reacting to cases such as Alstom and BNP Paribas, and the German to cases such as VW and Deutsche … Continue reading American Legal Imperialism?
During my tenure as the Compliance Counsel Expert at the Fraud Section in the Criminal Division of the U.S. Department of Justice, I consulted on the monitoring of compliance programs – through either self-reporting or monitorships - after the companies had resolved their cases. My time at the Fraud Section also saw the imposition of … Continue reading On Corporate Monitorships