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January 1 often kicks off with intentions: New Year’s resolutions. The importance of intentions also surfaces widely in spiritual, political, literary, and philosophical works too numerous for a blog, as well as in criminal law (e.g. intentional murder versus manslaughter) and various social interactions (“it’s the thought that counts”). However, in ethics oversight organizational leaders all too often fail to clarify the intentions underlying ethics initiatives. That is, instead of focusing on intended ethics outcomes, they stop short and consider the analysis complete upon identification of a list of ethics actions. (more…)

Perfection is not possible … imperfection is not an excuse The recently updated guidelines to the United States Foreign Corrupt Practices entitled A Resource Guide to the U.S. Foreign Corrupt Practices Act (November 2012) offers myriad helpful principles, case studies, and clarifications to facilitate compliance and proactive engagement with the authorities on various issues potentially covered by the FCPA. However, perhaps the most useful and reassuring guiding principle appears late in the document in Chapter 5 “Guiding Principles of Enforcement”: neither the Securities and Exchange Commission (SEC) nor the Department of Justice (DOJ) seek perfection. Nor should you. (more…)