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“Domestic Workers Who Have No Involvement In Foreign Sales Probably Don’t Need Training In The FCPA” – WRONG!


Navex Global claims to be the “ethics and compliance experts” and offers training courses that presumably seek to minimize a business organization’s FCPA risk.

However, in this recent post Navex asserts that “domestic workers who have no involvement in foreign sales probably don’t need training in the FCPA.”

This assertion is wrong on so many levels and if followed actually increases – not decreases – a business organization’s FCPA risk.

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Friday Roundup


Issue to ponder, scrutiny alert, laughable, silly, $50 million spent in approximately 9 months, and for the reading stack. It’s all here in the Friday roundup.

Issue to Ponder

If the FCPA and U.K. Bribery Act “have been broadly effective in addressing and remediating corrupt practices within … companies [subject to the laws]” as asserted in this article, then why – generally speaking – is there more (not less) enforcement actions under these laws over time? 

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The Non-Story Of Hui Chen Leaving Her Contract Consulting Expert Position At The DOJ


In this recent podcast, former DOJ contract consulting expert Hui Chen says that her first draft of the February 2017 “Evaluation of Corporate Compliance Programs” policy document was dated January 21, 2016 but the Obama DOJ never publicly released the document. She also says that DOJ prosecutors don’t even read the compliance regulations they are subject to.

From my perspective, the rest of the extensive – often over-the-top and often misleading – media coverage concerning Chen leaving her contract consulting expert position at the DOJ (which she began during the Obama administration) because she has strong opinions about the Trump administration and in her words “I want to help elect candidates who stand for [values she shares], and [she] cannot do that while under contract with the Criminal Division due to Hatch Act restrictions” is a non-story.

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FCPA Flash – A Conversation With Joseph Spinelli Regarding Risk Assessments and Compliance

FCPA Flash

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Joseph Spinelli (Senior Managing Director at Kroll). During the podcast, Spinelli discusses: risk assessments; the role various business personnel besides legal can play in FCPA compliance; and the use of technology in third party compliance.

FCPA Flash is sponsored by Kroll. Kroll is trusted by companies and compliance officers worldwide to help prevent, detect, and remediate FCPA challenges with scalable, end-to-end compliance solutions: from high-volume third party screening and automated monitoring, to risk-based due diligence, to complex investigations and monitorships.

“Compliance Officer” / Dad

Compliance Officer Dad

Today is Father’s Day.

With twin 9-year old boys, Father is just one of my titles. Referee and Compliance Officer being the others. As to the later, I guess Co-Compliance Officer along with my wife is the more accurate title (I wonder what the “Compliance 2.0” folks would say about this structure)?

Father’s Day is a chance to reflect and to be sure being a Dad has informed my view of many things including compliance.

When you really think about, compliance and parenting have a lot in common.

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