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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

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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

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Last week, I had the privilege and pleasure of engaging in a speaking tour in Brazil. It is particularly meaningful to me that Brazil was where I kicked off my post-DOJ public life: it is a country that I love for its people, music, and food, and one which has been rocked, politically and economically, … Continue reading Reflections from Brazil

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Interesting to see my quote interpreted below (reminder: links ≠ endorsements). My point is not to dispute the need for policies. My point, however, is to continually challenge companies to articulate what the goals and objectives of each of their policies are, and how they are measuring effectiveness against those goals and objectives. Here are … Continue reading Do Policy Binders Matter?

The mission: to make a difference.  There is much work to do not only in taking corporate ethics & compliance to the next level, but also in raising the moral consciousness of societies. To those ends, I will engage publicly through speaking, writing, and consulting, working with not only corporations interested in enhancing their ethics … Continue reading Mission Matters