All FCPA Guidance articles

  • Blog

    CCO authority and independence


    The more the Justice Department talks about CCO independence, coupled with resources being made available and authority concomitant with the CCO position, the more corporations will see it is in their best interest to provide the resources, authority, and gravitas to compliance positions within their organizations.

  • Blog

    Happy Birthday to the FCPA Guidance


    The joint Department of Justice and Securities and Exchange Commission  2012 FCPA Guidance came out five years ago this month. All compliance practitioners should thank the government regulators and prosecutors who had a part in drafting this most remarkable of documents.

  • Blog

    What is your investigation protocol?


    When viewing compliance as a clear series of steps leading to an effective goal, CCOs should take into account Hallmark 8 in the Ten Hallmarks of an Effective Compliance Program as supplemented by information from the Justice Department in its Evaluation of Corporate Compliance Programs.

  • Blog

    Internal reporting: hotlines and listening


    A look inside at some  of the best practices for a hotline.

  • Blog

    Anti-corruption efforts slowly gain steam in Latin America


    A majority of executives in Latin America may think their country’s anti-corruption laws are ineffective, but a recent survey by  law firm Miller & Chevalier and 13 partner firms based in the region offers evidence of region-wide improvements in corporate compliance measures. Joe Mont has more study details.

  • Blog

    Marrying Compliance Culture to Compliance Behavior


    Image: A study by the Cranfield School of Management has identified five key concepts for companies to employ toward effective risk management. In a nutshell: anticipate problems; have adequate resources; flow information to the board; respond quickly to any incidents; and learn from the past. CW’s Tom Fox has more ...