I spoke at a dinner tonight hosted by Resources Global Professionals. My co-panelist was Oliver Armas from Chadbourne. The dinner was wonderful, and Ollie fantastic. I hope I rose to that level.
We spoke about how the current state of FCPA enforcement is still rising, and how corporate compliance can best serve their businesses. As my friend and former colleague Laura Notes pointed out, compliance is supposed to be—and must be—owned by the business.
Ollie pointed out that it’s not just “tone at the top” that regulators want to see, it’s “commitment at the top.” Are senior leaders engaged and committed to compliance? I believe in the importance of “tone at the bottom.” Meaning, if you want to change behavior, you need to influence the first-line managers. When people need advice, they don’t go to the CEO, they go to their boss.
I think we scared some people, but the evening, I think, was a success.