As most of you who’ve heard me speak or read my columns know, I’m a strong supporter of using data analytics in compliance programs. It’s an important tool that all compliance professionals should have a working understanding...more
By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Management Systems ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Internal Controls ,
Pilot Programs ,
Reporting Requirements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Civil Monetary Penalty ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Employees ,
Ethics ,
Internal Investigations ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
United Arab Emirates (UAE)
This year’s annual Compliance Institute (CI) provided a strong reminder of just how fortunate we are to have such a strong relationship with the U.S. Department of Health and Human Services Office of Inspector General (OIG)....more
Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more
7/15/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Communications ,
Corporate Culture ,
Corporate Governance ,
Employees ,
Ethics ,
Internal Controls ,
Policies and Procedures ,
Strategic Enforcement Plan ,
Training
Anytime a compliance violation occurs—or even a breakdown in compliance controls that doesn’t ultimately result in noncompliance—the remediation process takes center stage. And this is where questions of how and why are...more
6/4/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Enforcement ,
Healthcare ,
Internal Controls ,
Noncompliance ,
Policies and Procedures ,
Remediation
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
6/4/2024
/ Anti-Bribery ,
Anti-Corruption ,
Best Practices ,
Bribery ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Governance ,
Corruption ,
Ethics ,
Noncompliance ,
OECD ,
Regulatory Requirements ,
Risk Management
A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more
4/26/2024
/ Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Disclosure ,
Ethics ,
Internal Controls ,
Internal Investigations ,
Risk Management ,
Self-Reporting
There’s good and bad news out there for compliance departments, and it’s also the same news: Governments now very much appreciate strong compliance programs.
On the one hand, that is very good (if not great!) news....more
There it is on page 39, under “Compliance Leadership and Oversight: The Compliance Officer’s Primary Responsibilities”:
“. . . the compliance officer should not lead or report to the entity’s legal or financial...more
Inspiration for this month’s column comes from our local newspaper in the Twin Cities, the StarTribune, in a column by Ross Levin. Levin discusses the psychological distinction between running towards something versus running...more
Two stories in the news recently caught my eye. In the first, a janitor allegedly shut off the power to a freezer after hearing “annoying alarms.” He ended up ruining decades of research. In the other story, an American...more
Hotlines are an incredibly valuable tool for identifying compliance issues and many other problems. Every organization should have a system for people to report—either anonymously or with reporter identification....more
The Wall Street Journal recently reported that the CEO of Uber spent time driving for the company under an assumed name. He filled out the forms like any prospective driver and drove around customers....more
On April 24, at this year’s Compliance Institute, the U.S. Department of Health & Human Services (HHS) Inspector General (IG) Christi Grimm announced an important initiative, which was posted in the Federal Register the next...more
As I write this in early April, we are fresh off an invigorating 11th-Annual European Compliance & Ethics Institute (ECEI) held in Amsterdam. ECEI was an in-person-only gathering of more than 300 people representing 30...more
A recent news report reminded me of how difficult it can be to manage compliance and environmental, social, and governance (ESG) risks. You may have seen the report: a tiny capsule the size of a small coin fell out of a truck...more
Don’t look now, but the noisy debate over artificial intelligence (AI) has risen a few notches with the recent introduction of ChatGPT. AI has been a topic of conversation for several years, but ChatGPT has taken everyone’s...more
5/3/2023
/ Artificial Intelligence ,
Automated Systems ,
Bots ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Machine Learning ,
Risk Assessment ,
Risk Management ,
Technology
As winter starts to recede, thoughts turn to warmer days and the need to embark on the traditional spring cleaning. While that’s usually an at-home affair, it can and should also apply to your compliance program. And while a...more
This month’s column is devoted to the idea of “testing out” of compliance training, a topic I addressed in my opening comments at the Compliance & Ethics Institute in October, but in a clumsy manner. I think I came across as...more
I managed not to lose my temper when a training skeptic informed me that he wasn’t a fan of compliance training because “it’s not going to make a dishonest person do the right thing.” Indeed, I doubt anyone who previously had...more
2/2/2023
/ Best Practices ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Employee Training ,
Employees ,
Ethics ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
Training
CT magazine (October 2022) -
Last month, I wrote about succession planning in the compliance department, an important concept we should always consider to avoid a big gap when the chief compliance officer, or anyone else...more
CT magazine (October 2022) -
Flying a plane is an incredibly complex job that requires tremendous amounts of training. Yet, when a pilot is suddenly unavailable, the airline usually locates another pilot who is equally...more
CT magazine (September 2022) -
Flying a plane is an incredibly complex job that requires tremendous amounts of training. Yet, when a pilot is suddenly unavailable, the airline usually locates another pilot who is equally...more
CEP Magazine (August 2022) -
The Association of Certified Fraud Examiners (ACFE) has been publishing a study on fraud every two years since 1996. This year’s edition, Occupational Fraud 2022: A Report to the Nations, is...more