Show notes: 00:01: Introduction to Episode #54, 03:54: “Thank you, Howard, for that kind introduction,” says Lanny Breuer, and more on the IBC Conference in London. Including how impressed I was with a guy named Chad Fentress, the CECO of Nokia. 09:35: UK “guidance” and UKBA enforcement (plus, TWIFCPA is big in Europe) 18:04: Tyco. […]

Tom and I discuss HP, NCR & how NOT to react to whistleblowers, the new and improved DOJ web site, Comverse Technologies and a lenient sentence for Paul Cosgrove. Episode #53.

I rant a little bit about the French and the fine they imposed against French aerospace and defense company Safran. A €500,000 fine for a bribery scheme that netted them a €170 million contract. I'm an anti-bribery advocate, and I'd make that deal. A 34,000% ROI.

Tom and I talk about Tom’s talk tomorrow in Chicago, News Corp.’s latest arrest, Safran’s ridiculously low fine, how much an investigation should cost (more if you’re Walmart, versus ABM), the SFO and gifts, Harris Corp. and gifts, and more! Show notes: 00:41: Go hear Tom in Chicago, Tuesday morning at the University Club of […]

In our weekly anti-corruption catch-up, Tom and I talk about Oracle, the SEC's extractive disclosure rule, $50,000 to a whistleblower, who's your state-owned entity, Peterson and accepting responsibility, and more!

Your finance people are absolutely crucial to your FCPA program. Do you know who they are? What their viewpoint is? What pressures they're under? They can help you with two of your most important program elements: transactional diligence and internal controls.

All about the Pfizer action and the DPA. Lessons to learn from a company that has been taking FCPA seriously for longer than most.

Tom and I talk about Pfizer (a little), Standard Chartered (more), EADS, News Corp., and more on Episode #49 of This Week in FCPA.

I talk about the importance of context in evaluating potential FCPA violations. No inappropriate behavior occurs in a vacuum. Companies who can show that they take anti-bribery seriously can easily weather an inquiry by the DOJ or the SEC.

A busy FCPA week: investigations starting, investigations ending, CEOs asked to come in for interviews, Stroz Friedberg picks up another one, and a rant about CDOs, the financial crisis, and dumb money.