Six Do’s and Don’ts for Due Diligence Questionnaires

“Wait, they want three months of the CEO’s personal bank statements? Are they insane?” This was a real request to one of my clients via a due diligence questionnaire. When I called to inquire with the requesting company why they needed this, they said that they wanted to ensure that the CEO wasn’t receiving “unusual payments” that could be a bribe.

This raised several questions. First, how could they tell if the payment was “unusual?” If we look at the history of bribes, most of them go out through a business account of some sort, not the CEO’s. And what about the logistics of where all of this personal information will be stored and who will be reviewing it…

Survey Says! What Your Priorities are for 2023

In January, we surveyed the compliance community to find out what your priorities are for 2023.
We asked about what you’re focusing on this year, the most important thing you’re working on, and the area of law you’re most focused on this year.

2023: Right-Skilling for Your Job

Many people feel that they are at the whim of their boss – as if they have no control over whether they are at risk of being fired.

Instead of leaving your fate to chance, start the year off right by taking control of your opportunities by right-skilling.

When Was the Last Time You Slept?

I recently watched Matt Walker’s TED Talk, “Sleep is Your Superpower,” and I was absolutely shocked at what he had to say.

And a bit terrified.

Year-End Budget Left? Where to Spend It!

It’s that time of year when we heed the warning about budget – use it or lose it!
If you find yourself in the lucky position with some year-end cash, here are some great ideas for where to spend it, and some strategies to try to get the most bang for your buck.

Five Important Lessons for Compliance Officers from the Oracle FCPA Settlement

Oh, recidivists.

If you’ve already been fined for bribery, don’t do it again! Alas, for Oracle, history has repeated itself with a second series of FCPA violations. The facts, as laid out in the SEC Order, are pretty fascinating.

But more important are the lessons that can be learned to ensure our programs better prevent and detect bribery and misconduct.

Compliance Champions? Yes , please – but what’s best? Part II

When Spark Compliance is doing a compliance program review and an organization doesn’t have a Compliance Champions program, guess what becomes a key recommendation? That’s right – starting a Compliance Champions program. Why?
Well, a Champions program has many benefits…

Compliance Champions? Yes please – but what’s best? Part I

Who doesn’t love the idea of having an expanded reach?

Having people showing up throughout the organization holding the banner of compliance? Keeping you informed as they act as the eyes and ears on the ground in a way impossible for your valiant team (perhaps, your team of one)?

Compliance Champions are a great way to make all of this happen.