Emtrain Blog

UC Chancellor’s Last Stand Is Yet Another Conflict of Interest

Posted by Janine Yancey

May 12, 2016

Whether right or wrong, UC Davis Chancellor Linda Katehi has been riddled with conflicts of interest: a board seat at a competing institution, using university funds to manipulate how information about Katehi and the infamous University pepper spray incident appears on the web, significant salary increases to her family members on university payroll, and more.

Most of these potential conflicts could have been easily avoided had Katehi used a simple ethics rule, which I like to call the Ricky Ricardo rule.

The Ricky Ricardo Rule: If you’re doing a lot of ’splainin’, you’re in a problematic situation.

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Topics: Compliance, Business Compliance, Code of Conduct, Ethics

3 Smart Ways to Safeguard Your Company from an Ethics Scandal

Posted by Allison Baker

May 3, 2016


A few years ago, Elizabeth Holmes’ company Theranos made headlines for its promise to disrupt biotechnology with innovative blood testing. Now, Theranos is making headlines for allegedly fooling investors, consumers, and the media that they had a viable product.

In addition to media scrutiny, Theranos and Holmes are currently under investigation by the SEC and DOJ. So, what happened here and how can we learn to build a company that doesn’t run into ethical and legal scrutiny after years of hard work?

Keep reading to find out how to build an ethical and compliant company from the start and avoid an ethics scandal.

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Topics: Compliance, Business Compliance, Code of Conduct, Ethics, Corporate Governance, onboarding, Silicon Valley

Why the SEC is Keeping an Eye on Silicon Valley Unicorns

Posted by Janine Yancey

April 28, 2016

In the late 1990s, there was massive investor confidence in companies with little or no earnings, no profits, short track records, and sometimes, no product. As a result, company valuations skyrocketed and a small percentage of people made millions.

Inevitably, the wind started to blow in the other direction and companies were directed to get cash flow positive quickly. That’s when fantasy company valuations plummeted and both employees and investors were left with little to show for their investment of time and money.

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Topics: Compliance, Business Compliance, Code of Conduct, Ethics, ethical workplace culture, Silicon Valley

FCPA Enforcement News: What You Need to Know From Q1

Posted by Allison Baker

April 8, 2016


The following post was adapted from a blog post written by our contributing editor, Professor Mike Koehler, and a version of it originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption course.

If you've been paying attention to FCPA enforcement news over the last few months, it's no surprise that the list of Q1 actions is a long one.

Keep reading for a full summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2016.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

FCPA Enforcement Update: What You Need to Know From Q4

Posted by Professor Mike Koehler

January 12, 2016

The following post was written by our contributing editor, Professor Mike Koehler, and originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption course.

This post provides a summary of Foreign Corrupt Practices Act enforcement actions and FCPA related events from the fourth quarter of 2015. (See similar posts here, here and here for Q1, Q2 and Q3).

Here are the FCPA enforcement updates from Q4:

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

The Senate's FCPA Hearing: A Look Back

Posted by Professor Mike Koehler

December 16, 2015

The following post was written by our contributing editor, Professor Mike Koehler, and originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption course.


Five years ago, the Senate held a hearing titled “Examining Enforcement of the Foreign Corrupt Practices Act.”

See here for the full hearing transcript, here for the full video.

It was the first congressional hearing on the FCPA during its new era of enforcement (to be followed by a June 2011 FCPA hearing in the House) and the first FCPA hearing in Congress since the FCPA was amended in 1998.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

9 Free Ethics & Compliance Videos to Share with Your Team

Posted by Janine Yancey

November 10, 2015

Video training tools are a hot item in the compliance world. I spoke with several compliance officers and CCOs across multiple industries and they all want the same thing: short video lessons that can be easily viewed and distributed.

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Topics: HR, Compliance, Insider Trading, Code of Conduct, Ethics

FCPA Enforcement: Why the Meaning of "Foreign Official" Matters

Posted by Professor Mike Koehler

September 8, 2015

The following post was written by our contributing editor, Professor Mike Koehler, and originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption course.


For some time, certain people have been confused, perplexed etc. as to why the meaning of foreign official in the FCPA’s anti-bribery provisions matters.

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

Do Your Hiring Practices Live Up to the SEC's New Expectations?

Posted by Professor Mike Koehler

August 25, 2015

The following post was written by our contributing editor, Professor Mike Koehler, and originally appeared on his FCPA Professor website. Professor Koehler developed our Global Anti-Bribery and Corruption courseware.


There are two distinct questions that can be asked in connection with many instances of Foreign Corrupt Practices Act scrutiny and enforcement.

The first is whether, given the DOJ’s and/or SEC’s enforcement theories, the conduct at issue can expose a company to FCPA scrutiny and an FCPA enforcement action?

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Topics: Compliance, Business Compliance, Corporate Governance, FCPA

Antitrust & Airlines: How to Avoid a DOJ Investigation

Posted by Robert Connolly

July 15, 2015

The following post was written by our contributing editor, Robert Connolly, and originally appeared on his Cartel Capers website. 


At a recent trade association conference in Miami of the International Air Transport Association (IATA), multiple airline executives spoke publicly about their plans to be “disciplined" in their approach to pricing and adding extra flights on popular routes.  

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Topics: Compliance, Business Compliance, Corporate Governance, anti-trust