Compliance Communications Blog

Joel A. Rogers

Recent Posts

Should Compliance Programs Mix With Corporate Social Responsibility?

I stay out of debates about the nature of compliance and how a compliance program should function, except in cases where the argument is related to how we communicate our compliance messages to employees.  One such debate was framed nicely in the latest issue of Compliance & Ethics Professional, SCCE’s magazine.



The First Step Toward FCPA Compliance: Stop FCPA Training Employees

OK, don’t flip out. I don’t mean that the way it sounds; I just said it that way so you’d read my blog which you’re doing. So you have to admit that it worked.

But, in another sense, I mean it quite literally. Here’s why: the other day, I saw yet another basic training presentation about the FCPA designed to educate employees about bribery. The presentation included the following sorts of facts:



Are Your Compliance Topics Getting Lost In Translation?

A piece published on entitled Watch your Languages in International Compliance caught my eye the other day. This is in part because it amazes me that anyone is still trying to convince anyone about publishing anti-corruption and other compliance materials for your employees that speak languages other than English; of course you have to do this, and I believe few people would argue the point. Not surprisingly, appropriate translation of compliance materials was listed as a “Hallmark of Effective Compliance Programs” in the FCPA Resource Guide published by the DOJ and SEC in 2012.



What ‘A Christmas Carol’ Teaches Us About Compliance Training

Purists of a certain sort will argue (as purists are wont to do) that the ne plus ultra of adaptations of Charles Dickens’ A Christmas Carol is the 1951 film version starring Alastair Sim as Ebenezer Scrooge.  I beg to differ, as my kids and I have been watching the Mr. Magoo version again lately, and I find that the sound of Jim Backus’ voice is deeply tied up in my psyche with the aesthetic of the holiday season.  Plus there are some really wonderful songs in that cartoon!  (“Ringle, ringle, coins when they mingle make such a lovely sound…”)

But no matter!  Whatever version compels you, compliance and ethics professionals should take careful note of this tale.  Why?  Because corporate compliance and ethics is fundamentally about changing behavior.  (Of course it is also very much about tracking, testing systems that track, and investigating behavior, but in the first instance it is about exerting an influence on employees’ behavior.)  And this is one story, albeit a fictional one, which illustrates just how powerful



The #1 Enemy For Compliance Professionals

The importance of simplicity has long been lauded in matters both physical and metaphysical.  Einstein is credited as having said, “Everything should be as simple as it can be” (of course he adds – in a nod to completeness – “but not simpler.”)  William of Ockham, 14th century English Franciscan friar and scholastic philosopher, is best known for his problem-solving principle that says that among competing theories, the one containing the fewest assumptions (absent other evidence for complexity) is the best one.  This cutting away of every “superfluous ontological apparatus” is famously known as “Ockham’s Razor.”