Practical insights for compliance and ethics professionals and commentary on the intersection of compliance and culture.

Round-up on justice issues with marijuana legalization

The ongoing discussion about marijuana legalization has gained great momentum and now must include vital justice considerations.  As the process of decriminalizing marijuana cultivation, use, and possession gains public acceptance, the scope of the discourse must widen to include racial and social justice reforms.  These issues are critical for understanding in the mixed progress of legalization, the efficacy and impact of enforcement trends, and ongoing requirements for regulatory design and social equity gains.

Cory Booker, US Senator from the state of New Jersey, is the author of the Marijuana Justice Act and has spoken repeatedly about the need for states to consider criminal justice reforms alongside medical and recreational marijuana legalization campaigns.  As states legalize future marijuana possession, use, and distribution but do not consider corrective action for people with previous criminal convictions they create an unjust and unfair double standard where legalization benefits one set of citizens and does not alleviate what Senator Booker refers to as “collateral consequences” that seriously impair another set.



TOMS is a well-known California-based retail company.  The company sells footwear, eyeglasses, coffee, clothing, and handbags.  Its most iconic item is the alpargata shoe, a casual style based on a traditional Argentine shoe.  The TOMS business model began with this shoe, and every time TOMS sold a pair, a new pair was given to a child without adequate footwear.  As the TOMS product line expanded, this philanthropic mission was extended to each of the new business items.  With each pair of glasses sold, TOMS uses part of the profit on vision projects in the developing world.  In honor of each purchase of TOMS coffee, the company works with partner organizations to provide water to communities in need.  Handbags sold benefit maternal health and safe childbirth initiatives.

Corporate social responsibility (CSR), therefore, is a significant driver of the TOMS business strategy and purpose.  The company was started by entrepreneur Blake Mycoskie with the entire purpose of serving as a philanthropic project to provide shoes to children in developing nations.  Throughout the company’s history since, raising awareness of the importance of having shoes for best health and safety practices.  The TOMS “one for one” business model where a charitable contribution is made for each purchase imbeds CSR in the commercial strategy of the company.


Corporate takedowns: Facebook and Cambridge Analytica

This is the third in a series of four posts about corporate takedowns.  The first post was about American Apparel.  Last week’s post was about Theranos.  Today’s post is about Facebook, focused on the recent Cambridge Analytica data sharing revelations.  The fourth and final post, on April 24, will discuss Gawker.

For an in-depth discussion of general compliance issues with Facebook as an online platform, check out this post.

In March 2018, The New York Times and The Guardian published a series of investigative articles exposing a data breach between the social media platform Facebook and the UK political consulting firm Cambridge Analytica.  This has incited a firestorm of controversy around data sharing, privacy expectations, online community moderation practices, and ethical standards for consumer protections by companies holding their data.


This week on Compliance Culture

Be sure to visit Compliance Culture this week for posts on these topics.

  • Monday:  Compliance and tax
  • Tuesday:  Corporate takedowns: Facebook and Cambridge Analytica
  • Wednesday:  TOMS and CSR
  • Thursday:  Marijuana legalization and justice
  • Friday:  Legalized marijuana in television

Don’t miss it!


Last week on Compliance Culture

Check out last week’s posts on Compliance Culture, in case you missed or want to revisit them.

Many thanks for reading!


Round-up on compliance issues with online platforms: Reddit

This is the final post in a series of six on compliance issues with various online platforms.  The first post was about YouTube.  The second post was about Facebook.  The third post discussed Instagram.  The fourth post was about Twitter.  Last week’s post covered Snapchat.  Today’s post, the sixth and final post in the series, is about Reddit.

Reddit is a web-based forum where users share links to news, photos, and videos, as well as engage in social media-style discussion threads.  Founded in 2005, Reddit has become one of the most visited websites in the world.  The platform is set up as a variety of user-generated community boards called “subreddits.”  These subreddits cover a wide variety of popular culture, current event, and special interest subjects.


Spring Break on Compliance Culture, Part 2

Compliance Culture is going on another short spring break hiatus to work on some new and exciting things coming soon! Check back on Thursday, April 26, when regular content for these two weeks will be available.  The routine daily posting schedule will also resume at that time.

Until then, enjoy browsing the tags and archives, or click SURPRISE ME! on the menu bar at top for a random post.

See you soon!


Top 10 FCPA Resolutions

The Foreign Corrupt Practices Act (FCPA) is a United States federal law which addresses accounting transparency and bribery of foreign officials. The US Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) are both responsible for FCPA enforcement – the SEC, for those companies under its regulatory jurisdiction, and the DOJ, for all other companies.  This enforcement famously leads to large settlement payments by offending companies, the resolution of which is often reached by collaboration among numerous governments and supervisory entities.

The ten largest FCPA resolutions as of the writing of this blog post are listed below, with links to more information and business case studies on each.