Former Defense Secretary Donald Rumsfeld, when speaking about the Iraq War, took a lot of “writ” for saying there are unknown unknowns and that the unknown unknowns are difficult to manage. No doubt it is a weird statement on its face. But, most folks who manage risk for a living understand that the unknown unknowns…
FOCI – Foreign Ownership, Control and Interest Given the information and technology that U.S. defense contractors have and the role they play in U.S national security, U.S. defense contractors need to be particularly concerned about the dangers of the world. To manage the wild and dangerous world, regulations, particularly those detailed in the National Industrial…
“Oh baby, baby, it’s a wild world.” -Yusuf Islam, formerly known as Cat Stevens To assist businesses in operating in this wild world, the U.S. government tries to pass laws that it thinks will protect businesses and U.S. national security. The Foreign Agent Registration Act (22 U.S.C. 611 et seq.; 28 CFR Part 5) (FARA)…
Whether your organization is building an anti-corruption program from scratch, or improving an existing one, it can be an intimidating, time-consuming and costly process. Either way, thinking about an anti-corruption program strategically and holistically can build efficiencies and effectiveness. A holistic approach to an anti-corruption program allows leadership to provide strategic direction and to actually…
At times, corporations and their leaders fumble when assessing legal risks. The result is trouble – corruption, procurement fraud, securities violations, inflated earnings, and trade violations. When it happens, it often results in criminal prosecutions, shareholder lawsuits, and negative media creating a perception that companies are filled with scoundrels. Often the prosecutions, the lawsuits and…
Do ethics and compliance have a price? Yep, and it varies depending on the scenario. But for this post, I am going to start my calculation at about $4.5 billion dollars. In 2015, Forbes Magazine put Ms. Elizabeth Holmes, founder and CEO of Theranos, on its list of the world’s richest self-made women with a…