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Ethics and Firing David Shulkin

We should never underestimate the Trump Administration’s ability to snatch defeat from the jaws of ethical victory. That certainly seems to be the case with last week’s firing of David Shulkin, now former secretary of Veterans Affairs. Compliance officers in the corporate realm should take note, so your CEO doesn’t shoot your ethics program in…

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Guest Column: COSO at a Tipping Point?


Nearly 30 years ago as young bank auditor, I learned about a private sector initiative known as “The Committee of Sponsoring Organizations of the Treadway Commission,” or more simply, “COSO.” It was the mid-1980s. The savings & loan crisis was raging. COSO was, and continues to be, a joint effort of five private sector organizations…

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About Those Tax Reform Bonuses…

CCO compensation

Today we step away from corporate compliance for a short detour into financial reporting, tax policy, and corporate governance. All those companies announcing bonuses, raises, and new employee benefits as a result of tax reform may not be as honest about their motives as their breathless press releases say. I did a quick analysis of…

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Another Vague FCPA Enforcement Action


The good news for compliance officers, as you may have already heard, is that we have another FCPA enforcement action under the Trump Administration— and yet again it’s a decision not to prosecute, because the company in question met all the criteria of the FCPA Pilot Program. The company is CDM Smith, a privately held…

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This Is How It Ends

It ends with President Trump leaving office before his full term, of course. I don’t know exactly how he’ll leave, or when. But the crucial question isn’t whether Trump’s departure is imminent; the question is whether his departure is inevitable. So just ask yourself: Do you really believe this man can fulfill his full four-year…

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Let’s Knock Down This Anti-FCPA Argument Now


The ethics & compliance community already knows we’re going to hear lots of chatter in coming months about easing the burden of compliance with the Foreign Corrupt Practices Act. We’ll probably see a new attitude at the Justice Department, shifting away from prosecuting organizations in favor of prosecuting individuals. We may see changes in the…

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Six Compliance Events to Watch in 2017

compliance 2017

Welcome back to the grind, everyone! Before we all go back to audit committee meetings, anti-corruption training, and committing your travel budget before the CFO implements a freeze, let’s take a look at what events in 2017 will carry big consequences for the compliance community. The arrival of the Trump Administration in particular sets up…

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This Weird United Airlines Case Just Happened


Fasten your seatbelts, compliance officers—we may just have flown into a vast, uncharted territory of corruption and internal control risk nobody expected. I speak of the SEC’s recent sanction against United Airlines, where the agency applied the spirit of the Foreign Corrupt Practices Act to a bribe United gave to a domestic government official here…

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Compliance in the Trump Era, Part II: FCPA


Last week we began an occasional series about how the incoming Trump Administration might affect the world of corporate compliance. Today we continue with a look at the future of the Foreign Corrupt Practices Act. First, let’s knock down the prospect of Congress revising the FCPA itself. Regardless of what Republican lawmakers say to score…

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Compliance in the Trump Era, Part I: The SEC


SEC Chairman Mary Jo White announced her resignation yesterday, firing the starting pistol for the Trump Administration to reshape financial regulation in this country. Compliance officers are uneasy about what the incoming Trump Administration might mean to them, and for good reason. Still, we have a few early clues to consider, so let’s try to…

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