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“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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The Challenges Of Detection And Prevention


The recent London Bridge attack in London. The January 2017 shooting at the Fort Lauderdale airport. The June 2016 shooting at an Orlando nightclub.

These recent instances, and several other similar acts of violence, have little in common with alleged Foreign Corrupt Practices Act offenses.

Except there is often a common thread in terms of the challenges of detection and prevention.

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Friday Roundup


Mebiame sentenced, a multi-billion dollar settlement in Brazil, remember that, and for the reading stack. It’s all here in the Friday roundup.

Mebiame Sentenced

As highlighted in this prior post, in August 2016 the DOJ unsealed a criminal complaint charging Samuel Mebiame, a Gabonese national connected to Och-Ziff, with conspiracy to violate the FCPA’s anti-bribery provisions in connection with African mining projects. In December 2016, Mebiame pleaded guilty. (See here).

Earlier this week, the DOJ announced that Mebiame was sentenced to 24 months in prison.

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DOJ Compliance Counsel Hui Chen Calls Out “The Lack Of Precision And Intellectual Rigor” In Much Compliance Writing And Commentary


Kudos to Hui Chen (the DOJ’s Compliance Counsel) for highlighting the “lack of precision and intellectual rigor” in much compliance writing and commentary.

In this weekend LinkedIn post titled “Precision Matters,” Chen highlights three recent articles / posts to demonstrate her points . Although she does not link to or cite the articles, it is clear that the offending articles include here and here from the FCPA Blog.

Frequent posts on FCPA Professor have highlighted the same (and other) problems Chen speaks of. (See the following posts among others: “All We Need Is Trust,” “Compliance 2.0 – A (Mostly) Meaningless Buzzword,” “Elevating the FCPA Conversation,” “You Gotta Be Kidding Me“, “Stop Drinking the Kool-Aid,” and “Blowing the Whistle on Recent Commentary“).

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All We Need Is Trust :)


It’s as predictable as the sun rising in the morning.

A corporate “crisis” happens and supposed compliance “commentators / gurus” or those with fancy self-made titles or institutional affiliations come out of the woodwork with the supposed secret sauce like “doing compliance,” “tone at the top,” “values-based culture” and my favorite “trust.”

Indeed, “Trust Your Employees, Not Your Rule Book,” was the title of this recent article in the Harvard Business Review.

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