Happy anniversary, Corporate Sentencing Guidelines

Monday, November 1 is the 30th anniversary of the Federal Sentencing Guidelines for Organizations, the set of legal standards that, more than any other, gave rise to the compliance & ethics field, In his 2008 book Experiments in Ethics, Anthony Appiah made a strong and important case that behavioral science ideas […]

The oldest conflict

Many years ago a client being vetted for a high-ranking post asked me if a question about prior ethical violations required him to disclose a long since concluded extramarital affair. I replied that this seemed beyond the scope of the question, and I would give the same answer if asked today. But […]

Conflict of interest expertise

Here is my latest column for Compliance & Ethics Professional. I hope you find it interesting..

Conflicts of interest: getting it wrong

In the nearly ten years that I have published this blog I have noted various studies and other sources of insight into the issue of whether individuals and organizations truly understand the negative impact flowing from disclosed COIs. See posts collected here.  (The latest contribution to this area is Bias […]

Making the most of your risk assessment (part 2)

Here is a just-published post on risk assessment from the FCPA Blog. I hope you find it useful..  

Combining COI program and risk assessments

COI risk assessments and program assessments are two different things. But they can overlap to some degree and so it makes sense to consider how/how much they should fit under “one roof.” This is particularly so when both procedures are based principally on employee interviews, with some danger of duplication. […]

The Spirit of Liberty – and Ethics

Learned Hand – considered by many to be the greatest of all US judges – once famously said:  “The spirit of liberty is the spirit which is not too sure that it is right.”   This is a spirit which sadly seems as distant from us today as it ever has […]

Measuring compliance measurement

  In a book chapter from the recently published Measuring Compliance: The Challenges in Assessing and Understanding the Interaction between Law and Organizational Misconduct,  Benjamin van Rooij,   University of California, Irvine School of Law, University of Amsterdam;, Faculty of Law; Melissa Rorie, University of Nevada, Las Vegas write: “A major question […]

Trust and the compliance officer’s remit

Trust has always played a vital role in developing and maintaining civilizations and other organized groups  – large and small  – of humans.  But it seems like trust in business is as important now as it has been before. As described in the Harvard corporate governance blog by PwC’s Paul […]

The $5800 bottle of booze

According to recent media accounts “The State Department is looking into the whereabouts of a $5,800 bottle of Japanese whiskey that was gifted to former Secretary of State Mike Pompeo, according to State Department filings in the federal register. The government of Japan gifted the whiskey to Pompeo in 2019, […]