Have I really not written anything since July 18th?  You’re probably sitting there by your RSS reader saying, “he never calls, he never writes….”

I’ve been travelling a lot, which is one reason, and I’ve been head-down on a couple of work projects.

So let me just refer you to an excellent post by Michael Volkov .  I say excellent not just because he refers to me in the title, and not just because he has a picture of me at the top of the post, but because he’s absolutely right.

I write and speak a lot on control convergence—the idea that the silos of compliance controls should be merged since we’re all looking for the same or very similar data.  OFAC compliance and FCPA/UKBA compliance is a no-brainer in my opinion for this kind of approach.  Same with anti-money laundering.  If your company has an FIU (mainly in banks and other financial institutions), and your FCPA/UKBA compliance team hasn’t tapped into that resource, you need a new FCPA/UKBA compliance team.  Remember, AML compliance is older, more structured, more mature, and has better resources.  If you need an AML compliance program, you need a good one, and you need it badly.  Companies can spend upwards of $100 million on AML programs.  Is there anyone out there who has spent that kind of money on FCPA/UKBA compliance?  I don’t think so.  Maybe Siemens, but most of their money was spent on internal investigations, not the compliance program per se .

So…go read Mr. Volkov’s post, and I promise new posts more regularly.