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This study explores ongoing research into self-mapped learning pathways that students utilize to move through a course when given two modalities to choose from: one that is instructor-led and one that is student-directed.

Process mining analysis was utilized to examine and cluster clickstream data from an online college-level History course designed with dual modality choices. This paper examines some of the results from different approaches to clustering the available data.

By examining how often students interacted with others, whether they were more internal or external facing with their pathway choices, and whether or not they completed a learning pathway, this study identified five general tactics from the data: Individualistic Internal; Non-completing Internal; Completing, Interactive Internal; Completing, Interactive, and Reflective and Completing External. Further analysis of when students used each tactic led to the identification of four different strategies that learners utilized during class sessions.

The results of this analysis could potentially lead to the creation of customizable design models that can assist learners as they navigate modality choices in learner-centered or less-structured learning design methodologies.

Few courses are designed to give the learners the options to follow the instructor or create their own learning pathway. Knowing how to identify what choices a learner might take in these scenarios is even less explored. Preliminary data for this paper was originally presented as a poster session at the Learning Analytics and Knowledge conference in 2019.

The purpose of this paper is to explain the joint guidance on the US Foreign Corrupt Practices Act (FCPA or the Act) published on November 14, 2012 by the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC).

The paper explains the principal provisions of the Act covered in the joint guidance, where the joint guidance sheds light, and where it leaves uncertainty. Key issues covered are jurisdiction; corrupt intent, knowledge and willfulness; the “business purpose” test; gifts, travel and entertainment expenses; charitable contributions; definitions of foreign officials and instrumentalities; third parties; facilitating payments; extortion/duress; successor liability; accounting provisions; compliance programs; compliance monitors; and prosecution, resolution and declination decisions.

While it is unprecedented in federal law enforcement that the DOJ and SEC have provided the public with such detailed information on their joint FCPA enforcement approach and priorities, the guidance does not break new ground and generally reaffirms positions the agencies have previously espoused in other contexts. The guidance leaves open some difficult issues facing compliance officers and practitioners.

The paper provides expert guidance by experienced financial services lawyers.