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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Now displaying: Page 1
Aug 27, 2018

As I end this month of the Land of 1000 podcasts, I conclude with a week of King Arthur and his Roundtable themed-podcasts. It turns out there are many compliance lessons from the entire oeuvre of Arthurian legends. Many of the tales can inform your (modern day) compliance program. I begin with King Arthur and some leadership lessons that might apply to a Chief Compliance Officer or the compliance practitioner.

According to the legends, King Arthur achieved quite a bit in one lifetime. He, established a kingdom, ruled his castle, Camelot and brought peace and order to the land based on law, justice, and morality. He founded an order known as the Knights of the Round Table where in all knights are seated as equals around the table, symbolizing equality, unity, and oneness. Nicole Lastimado, in a blog post entitled “Characteristics of a Good Leader :)”, identified five characteristics that she believed made Arthur a good leader.

Adapting Lastimado King Arthur was (1) Honest, in that he displayed sincerity, integrity, and candor in his actions. (2) Intelligent, because he read and studied. (3) Courageous, because he had the perseverance to accomplish a goal, regardless of the seemingly insurmountable obstacles. (4) Imaginative because he adapted by making timely and appropriate changes in his thinking, plans, and methods. Finally, (5) Inspiring, because through demonstrating confidence, he inspired his knights and those in his Kingdom to reach for new heights. I would add as a separate category that Arthur led from the front.

What are the lessons from for the CCO or compliance practitioner? You should channel your inner King Arthur and lead. You have to lead management to understand that one of the best sources of information on your own business is your employees. There is a reason the FCPA Guidance lists internal reporting as one of the Ten Hallmarks of an Effective Compliance Program. You must give employees a way to report misconduct and then you must use that information to investigate and communicate to employees going forward. If there are lessons to be learned use those lessons for in-house compliance training. If a true catastrophe or disaster befalls the company, do not wait to remediate. Do so as soon as is practicable, not when the government calls.

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