• FCPA

    Vantage Drilling, General Lee and the Culture of Compliance

    Gin is a noble spirit; without vermouth, perhaps a lonely one.  Similarly, having a compliance program, yet failing to follow it in the presence of some red flags is both lonely and expensive, as we see in the internal accounting controls FCPA case that Vantage Drilling recently settled with the SEC.  Is this a problem with culture?  And what is “culture,” anyway, in terms of FCPA compliance? Except perhaps for “paradigm” and “silo,” the word “culture” is one of the most abused in the vocabulary of compliance, ethics and consultants.  (I once heard a consultant say that he needed “a high hover over the silos.”  I thought it an ironic mash-up…

  • Compliance,  Parallel Proceedings

    FIFA Indictments, Corporate Compliance, Alfred Kinsey and Robert Lee

    Law360’s Zachary Zagger has a nice piece on the FIFA prosecution and quotes, among others, Jack Sharman: “Given this many defendants and the fact that there is going to be at least some who are going to cooperate, it would not surprise me if there wasn’t a second wave of charges or people coming out of the woodwork, people you have not heard of yet,” said Jackson R. Sharman III, a white collar criminal defense attorney with Lightfoot Franklin & White LLC. “If it is going to survive, it is going to have to have a more rigorous compliance structure than some of the items that have come across thus far,”…