Compliance Communications Blog

 

"SFO Director Green Talks Enforcement"


12/2/14:
For folks who missed the Pinsent Masons regulatory conference in London this fall, Richard Cassin gives an overview on his FCPA blog of David Green’s comments (the chief of the UK Serious Fraud Office). Green admitted that fraud was up – an all-too-familiar reality for compliance professionals – but so is enforcement by the UK’s Serious...

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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.”

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"One for You, One for Me"

11/15/14: Bid-rigging has become a familiar antitrust crime but the guilty plea by Aisin Seiki Co. Ltd., a Japan-based automotive parts manufacturer, resulted from its role in a conspiracy to allocate customers.  That plea agreement is costing the company $35.8 million. The scheme, according to the US DOJ, involved meetings and conversations between...

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"How DOJ Sees Compliance Programs"


11/1/14:
In his Conflicts of Interest blog, Jeff Kaplan posted an article drawn from the keynote address given by Marshall Miller from DOJ’s Criminal Division Practicing Law Institute’s Advanced Compliance & Ethics Workshop. Kaplan quotes Miller about a high-level commitment as a principal hallmark of an effect compliance and ethics...

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The Power Of "Because" In Effective Compliance Communication

In a recent entry on his always excellent blog, SCCE CEO Roy Snell talks about a  study in which the use of the word “because” is shown to be powerfully effective in influencing others.  (“We need to leave now” is presumably less effective than “We need to leave now because we are about to be late.”)  Roy makes a point about the quality and integrity of the “because.”  “We need to formulate our “because”… thoughtfully before we ask people to do things,” he says.  “People can see through and are not motivated by the ‘manufactured because.’”

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