Menu8/1/14: Facilitation payments continue to bedevil compliance officers, and for good reason. Tom Fox frames a post about facilitation payments by recognizing that they represent one of the most confusing elements of the FCPA. But, he notes, “Facilitation payments are small bribes but make no mistake about it, they are bribes.” So, how...
Compliance Communications Blog
Aug 01, 2014 •
8/1/14: Facilitation payments continue to bedevil compliance officers, and for good reason. Tom Fox frames a post about facilitation payments by recognizing that they represent one of the most confusing elements of the FCPA. But, he notes, “Facilitation payments are small bribes but make no mistake about it, they are bribes.” So, how...
Aug 01, 2014 •
8/1/14: A post by Julie DiMauro on the FCPA Blog provides a brief overview of the recent advisory from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on a “culture of compliance.” Aimed directly at leaders of financial institutions under FinCEN’s jurisdiction, the advisory notes the responsibility of those...
Jul 28, 2014 •
OK, so I get that that title begs a significant question, and I suppose there are employees in the world who don’t hate compliance training. Not sure I’ve met many of them, but I’m sure there must be some…
Actually, we know there are some. Last year, after surveying 100 compliance executives and 3,000 employees, the Corporate Executive Board reported that 32% of the employees said that the compliance training they had received held their attention through the whole course or courses. 39% said the training was relevant to their work, and 44% said that it was informative. The CEB’s public blog summarizes these findings nicely.
Jul 11, 2014 •
Is “marketing” a crass, commercial word that shouldn’t be associated with compliance programs?
About ten years ago I started proselytizing in earnest about the lessons that compliance professionals needed to be taking from advertisers and marketers. My slides used to say something like:
- The second time consumers see an advertisement, the familiarity and believability of its claims increases by more than 30% from the first time they see the ad.
- The third time they see the ad, its familiarity and believability increases by over 100% from the first time they saw it.
- It takes between nine and 21 impressions before a consumer is ready to buy a product.
Jun 18, 2014 •
Why do employees do things that violate the law or violate company policies? There are a lot of reasons, some of which have to do with a failure to understand the rules and some of which are about willful violation. But fundamentally, employee behaviors follow the same rules that all animal behaviors follow – they are ultimately driven at the level of pleasure attainment and pain avoidance.
