Welcome to The Woody Report, where Washington & Lee School of Law Associate Professor Karen Woody and host Tom Fox discuss issues on white collar crime, compliance issues, international corruption, securities and accounting fraud, and internal corporate…
From Reinspection Fees to Executive Signatures: Final Lessons from Scoular The Scoular Company FCPA enforcement action began with a deceptively simple fact pattern. Customs brokers allegedly paid Mexican officials approximately…
Today, we set a course for one of Star Trek: The Original Series’ most underrated yet profound episodes: “The Empath.” As compliance professionals, we know that the heart of any…
The Scoular Company Deferred Prosecution Agreement (DPA) ends where every effective compliance program should begin: accountability. The agreement does not leave anti-corruption compliance solely with the Chief Compliance Officer, legal…
Today, we’re setting our sensors on one of Star Trek: The Original Series’ most thought-provoking episodes—“Wink of an Eye.” While this story may not feature the grand courtrooms or battlefields…
The Scoular Company bribery scheme was hidden, but it was not invisible. For six years, customs brokers paid Mexican officials approximately $2,000 per train so Scoular Company shipments could cross…
In this episode of Trekking Through Compliance, we consider the episode Plato’s Stepchildren, which aired on November 12, 1968, and occurred on Star Date 5784.0 Story Synopsis The episode begins…
The Scoular Company Deferred Prosecution Agreement (DPA) presents a difficult but essential lesson for every Chief Compliance Officer and board: stopping misconduct is not the same as voluntarily disclosing it….
If you ask any veteran compliance professional what separates the ordinary from the extraordinary, the answer is almost always the same: the ability to investigate under pressure. In a world…
My earlier analysis of The Scoular Company FCPA enforcement action necessarily relied on the Department of Justice Press Release. That release described the government’s allegations. The formal Deferred Prosecution Agreement…
The worlds of science fiction and compliance may seem galaxies apart, but seasoned compliance professionals know that some of our most profound lessons come from the most unexpected places. Nowhere…
