Martin T. Biegelman, CFE, CCEP, has been fighting fraud and corruption for 40 years in various roles in law enforcement, consulting, and the corporate sector. He is currently the Executive Vice President of U.S. Operations for IPSA International, a global risk advisory firm. His extensive experience include conducting internal investigations on behalf of corporate management and boards, FCPA and anti-bribery compliance, litigation consulting, due diligence, and corporate compliance design and implementation. He previously served as the Director of Financial Integrity at Microsoft Corporation. This highly acclaimed fraud prevention and anti-corruption compliance program that he founded and led continues to be a model for other global companies. Mr. Biegelman is a sought-after speaker, prolific author, and the recipient of the prestigious Cressey Award bestowed by the Association of Certified Fraud Examiners for lifetime achievements in the detection and deterrence of fraud.

• Foreword xi Preface xiiiAcknowledgments xviiAbout the Author xixCHAPTER 1 Why Ethics and Compliance Will Always Matter 1CHAPTER 2 Tone at the Top and Throughout 25CHAPTER 3 The Growth and Evolution of Compliance 45CHAPTER 4 Caremark and Sarbanes-Oxley: Enhancing Compliance 71CHAPTER 5 CA's Compliance Rebirth: Don't Lie, Don't Cheat, Don't Steal 87CHAPTER 6 The International Landscape of Compliance 107CHAPTER 7 Compliance Programs and Anti-Money Laundering Efforts 131By Marc B. Sherman, Laura Connor, and David MeilstrupAbout the Chapter Authors 148CHAPTER 8 Interview with an Ethics and Compliance Thought Leader 149CHAPTER 9 Building a World-Class Compliance Program: The Seven Steps in Practice (Part I) 163CHAPTER 10 Building a World-Class Compliance Program: The Seven Steps in Practice (Part II) 191CHAPTER 11 Recognizing Compliance Excellence: Premier, Inc. and Winning the Baldrige Award 219CHAPTER 12 Designing Robust Fraud Prevention Policies: The Airservices Australia Fraud Control Plan 233CHAPTER 13 The Skunk in the Room 257Appendix A: Summary of the 2004 Federal Sentencing Guidelines Amendments and Recommended Action Steps 269Appendix B: Sample Compliance Program Charter 277Appendix C: Resources for Compliance Professionals 283Index 291