The line between holiday gift giving and corruption is very gray. You need to be concerned that traditional holiday gifts are not actually holiday corruption bribes. Not only should you look at an individual gift, you need to look to gifts to the organization as a whole. One excessive gift may seem over the top … Read more »
Right to Audit
From the KPMG 2008 Anti-Bribery and Anti-Corruption Survey: While 63 percent of those respondents that require periodic compliance certifications said they incorporate a right-to-audit clause in their third-party contracts, a significant majority of these (68 percent) has never exercised the right (see Chart 4). A right-to-audit clause appears to be the kind of oversight expected by … Read more »
KPMG 2008 Anti-Bribery and Anti-Corruption Survey
KPMG Forensic published its 2008 Anti-bribery and Anti-corruption Survey. KPMG surveyed 103 U.S. executives in the summer of 2008. At a time when bribery and corruption prosecutions and enforcement actions are on the rise across the globe, the results of a new KPMG LLP survey suggest that multinational organizations based in the United States continue … Read more »
Why I Love Twitter
Tim O’Reilly wrote a great peice: Why I love Twitter. Twitter is simple. Twitter works like people do Twitter cooperates well with others Twitter transcends the web Twitter is user-extensible Twitter evolves quickly Now that I have moved from The Firm to the New Company, I have been using Twitter much more. Since I have … Read more »
IT for GRC: Improving Information Quality
Carole Switzer, President of OCEG and Lee Dittmar, principal of Deloitte Consulting LLP presented this webinar. There is an imperative to improve governance, risk management and compliance processes to better manage risk, address increasing regulatory requirements, increased executive accountability and the fragmentation of information. It is about getting the right information, to the right person, … Read more »
Defining “Foreign Official” Under the Foreign Corrupt Practices Act
Jeffrey Clark of Willkie Farr & Gallagher moderated a conference on Defining “Foreign Official” Under the Foreign Corrupt Practices Act. David Stewart, U.S. Department of State and Georgetown University Law Center and Kathleen Hamann, U.S. Department of Justice led the discussion. They start with a quote: why is a raven like a writing desk? (From … Read more »
Evolution of Compliance
I watched a recorded webinar presented Complinet: Compliance Evolution: Lessons Learned, Forgotten and Ignored. (March 13, 2008) Betsy Prout Lefler, the Deputy Director of Compliance at Piper Jaffray and Co. gave the presentation. There are many different perspective on compliance and what compliance professionals do. In part because the role has changed very quickly. At … Read more »
LegallyMinded – The ABA Tries to Get Social
The American Bar Association launched LegallyMinded, a social networking site targeted at lawyers, paralegals, law librarians, law students and anyone else in the legal market. Being a student of social networks for lawyers, I thought I would sign up. I encountered my first problem when they asked me to have a username rather than my … Read more »
Things You Should Never Put in an E-Mail
Molly McDonough of the ABA Journal puts together a list of things you should never put in an email, borrowing from Roger Matus‘ 10 Things Never To Put In Email: “I could get into trouble for telling you this, but…” “Delete this email immediately.” “I really shouldn’t put this in writing.” “Don’t tell So-and-So.” Or, … Read more »
What are WIFs?
My notes from the EthicsPoint webinar on intake models and the value of web intake forms. The presenter was Erin Watkinson a business solutions consultant at EthicsPoint. A custom web intake form is a replacement for paper based forms. You can use the web to report on issues. Reporting should encourage employees to first go … Read more »