FCPA Compliance Report

Return of the Jedi – Effective Compliance Training


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Today we continue our celebration and exploration of the original trilogy of Star Wars movies with a look at Episode VI. Return of the Jedi. In this final movie from the original three, the good guys win in the end after overcoming incredible odds. Many fans and critics panned it for including the incredibly cute and furry Ewoks on the moon named Endor as a part of the storyline. Many thought one very tall Wookie was enough cuteness for the series. Yet the Ewoks did provide the setup to one of the movies best lines. The Ewoks thought one of Luke’s robots, C-3PO, was a god. Solo asked him to demonstrate some ‘god-like’ powers to which C- 3PO replied, “It is against my programming to impersonate a deity.”

This movie’s big reveal was that Luke and Princess Leia were twins and that she was now free to unabashedly pursue bad boy Han Solo. While Episode VI was the lowest grossing film of the original three, coming in at only $572MM worldwide, it was still a great ride and visually stunning. George Lucas’ in-house organ, Industrial Light & Magic (ILM), certainly earned their title for their special effects in the movie. The Sarlacc battle sequence was great, the speeder bike chase on the Endor moon was way cool and the space battle between Rebel and Imperial pilots was a great ride. At the Academy Awards ceremony for movies of that year, Richard Edlund, Dennis Muren, Ken Ralston, and Phil Tippett, all from ILM, received the Special Achievement Award for Visual Effects Oscar award.

I thought about this entry in the Star Wars oeuvre in the context of compliance training. One of the key changes from the Department of Justice articled in the 2017 Evaluation of Corporate Compliance Programs was the change in training. The DOJ wants both targeted and effective training. This means you must be able to demonstrate how your training has been received and utilized by your employee base.

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FCPA Compliance ReportBy Thomas Fox

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