FLAGSTAFF, Ariz. — Ryan Williams doesn’t look like a running backwho was lying on the turf at Lambeau Field after suffering aseason-ending knee injury against the Green Bay Packers just 341days ago.When training camp opened in Flagstaff for the Arizona CardinalsWednesday,Williams simply looked like the back the team drafted in the 2ndround of the 2011 NFL Draft out of Virginia Tech.Taking advantage of Beanie Wells being placed on the PUP(Physically Unable to Perform) List, Williams took on a sizableworkload in his first practice of camp — so much so, that itsurprised even himself. What an MLB source said about the D-backs’ trade haul for Greinke The crowd in attendance didn’t seem to mind, as they voiced theirapproval.“It was cool, I loved the support,” he said. “I’m sure a lot of peopleout there were paying attention to my rehab, my recovery and myprogress, so for them to be paying attention to rooting me on todayfelt good.”Despite his impressive first day, Williams knows there will becompetition for carries when Wells returns to practice followingoffseason knee surgery.“Beanie will be back, and he’ll be himself and I’m ready to do a 1-2punch,” Williams said. “That’s my bro, man. For the last two tothree months we’ve been in the rehab facility together and I feel likethis injury has brought us closer together.” – / 35 “I actually practiced more than I thought I would today, for my firstday,” Williams said. “They said I was going to be limited in my playsand everything so I didn’t know that I was going to run routes, Ididn’t know that I would get that many carries, and I really didn’tknow that I was going to get the ball on that screen.”If he was surprised, it didn’t show. The second-year pro lookedvery comfortable on the upper practice field at NAU, even if hebelieves he’s not quite at full strength just yet.“I do, I do,” Williams answered when asked whether he has anylingering effects from the torn patellar tendon in his right knee. “I’lladmit, I’m not 100 percent, but I’m as close to it as I’ve been sinceAugust.“If I were to guess, I’d say I’m about 85 or 90 (percent), sothroughout the rest of this month and August, I’m trying to get thatlast ten to 15 percent back.”Williams had one of the highlight moments of Wednesday’s practicewhen he took a handoff from quarterback John Skelton, side-steppeddefensive lineman David Carter and zig-zagged thoughseveral defenders on what would have been a long gain. Thepractice, after all, was a non-contact walk-through. D-backs president Derrick Hall: Franchise ‘still focused on Arizona’ Comments Share Cardinals expect improving Murphy to contribute right away Nevada officials reach out to D-backs on potential relocation Top Stories
Understanding the answers to the above questions and incorporating them into an FCPA compliance program are leaps and bounds more important than “tone at the top” and the specifics of the reporting relationship between a chief compliance officer and the board of directors.Moreover, Compliance 2.0, like most buzzwords, can be counter-productive because they create a false sense of results by inferring that adherence to the buzzword will show results. Indeed, a recent survey by the Institute of Leadership & Management suggests that a meaningful percent of employees consider management jargon as pointless and often irritating.In short, decide for yourself whether Compliance 2.0 is a useful concept or mostly a meaningless buzzword.And when you are done with that, turn your attention to Compliance 3.0 (see here). This recent article in the Journal of Judgment and Decision Making titled “On the Reception and Detection of Pseudo-Profound Bullshit” caught my eye. The article focuses “on pseudo-profound bullshit, which consists of seemingly impressive assertions that are presented as true and meaningful but are actually vacuous.”Perhaps you’ve noticed the emergence of the term “compliance 2.0” in the Foreign Corrupt Practices Act space and beyond?You can read a three part series on Compliance 2.0 (here, here, and here) on the FCPA Blog.You can read a five part series on Compliance 2.0 (here, here, here, here, here) on Corruption Crime and Compliance.Panels at conferences are titled “Compliance 2.0: How to Build and Implement a Strong Compliance Program for FCPA” and other areas.You can read the above links and decide for yourself whether those promoting Compliance 2.0 as some kind of secret sauce have a point or are mostly speaking in vague generalities and thus gobbledygook.My own two cents is that Compliance 2.0, as used in the FCPA space, is mostly a meaningless buzzword.Using the word “no” FCPA issue is a bit strong because, after all, a broken clock is right twice a day (pardon the buzzword / cliche).However, few if any FCPA issues are going to be “nipped in the bud” (pardon the buzzword / cliche) based on the following purported components of Compliance 2.0: the reporting relationship between a board of directors and chief compliance officer or general counsel; a CEO or other executive officer’s “tone at the top” (another mostly meaningless buzzword in the FCPA space); or consideration of other stakeholders.Rather, FCPA issues arise – and can thus best be mitigated and managed – by understanding how real people, operating in foreign countries with real business conditions, interact with real foreign officials.The narrative roadmap for many FCPA issues is as follows. How does the company’s product enter and exit the country? Does the company use the services of a customs broker or freight forwarder? How does the company do business and/or interact with customers or potential customers in the country? Does the company use third parties in the foreign countries? Who are the company’s customers or potential customers in each country? Is the customer a government (whether federal, state, or local) department, agency or instrumentality? Does a government department, agency, or instrumentality, or individual associated with such units, have an ownership or equity interest in the customer? Barriers, distortions and conditions create bureaucracyBureaucracy creates points of contact with foreign officialsPoints of contact with foreign officials create discretionDiscretion creates the opportunity for a foreign official to misuse their position by making bribe demands.Instead of complicating the compliance playbook with a mostly meaningless buzzword, business organizations should keep it simple and focus on blocking and tackling type issues (pardon the buzzword / cliche) such as the following questions relevant to conducting an FCPA risk assessment:In which countries does the company do business? As to each country, what is the country’s reputation for corruption? What licenses, permits, or certifications does the company need to do business in the country? As to each license, permit or certification, how does the company obtain such approvals? Is the company subject to other unique forms of government regulation in the country? What other points of contact does the company have with foreign government in the country (such as tax and immigration authorities)?