Among all the elements of a corporate compliance program, perhaps the most difficult piece to understand is the testing and monitoring of your controls. Clearly the two are important. The U.S. Justice Department says so in...more
Artificial intelligence keeps improving at all sorts of things – including how to challenge corporate ethics and compliance programs. Even while you may still be struggling to tame the risks of generative AI, its more...more
For many years, corporate compliance officers have followed a certain natural process. First, regulators adopt a new rule, then you decipher how the arrival of that new rule might require changes to your policies, procedures...more
3/26/2025
/ Artificial Intelligence ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Deregulation ,
Employees ,
EU ,
Policies and Procedures ,
Regulatory Reform ,
Risk Assessment ,
Risk Management ,
Trump Administration
The other day, I attended a panel discussion of compliance officers talking about how corporate compliance might change with the arrival of the Trump Administration. Except, we never got around to that discussion – we were...more
Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...more
2/20/2025
/ Anti-Bribery ,
Anti-Corruption ,
Compliance ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Governments
Compliance officers can learn a lot from small businesses, and today we have a fascinating example of that point from the smallest sort of business there is – a boy selling ice cream on the side of the road, who was soon shut...more
For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
12/8/2023
/ Board of Directors ,
CCO ,
CEOs ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Healthcare ,
Healthcare Reform ,
OIG ,
Risk Mitigation
Don’t faint from surprise at this news, but corporate compliance is a world with lots of lingo that can be difficult to understand. Case in point: a “policy about policies” – something that sounds obscure, but actually is one...more
Compliance and technology executives, we need to talk. Or, more accurately, you need to talk more often – to each other.
In the last 18 months, the Securities and Exchange Commission sanctioned three companies for making...more
As compliance officers enter 2023, they need to learn how to handle a double-edged sword: the Justice Department’s new requirement that as part of corporate misconduct resolutions, CCOs must certify the effectiveness of their...more
ChatGPT really is a marvelous technology – an artificial intelligence designed to answer just about any question a person might ask it – and yet, somehow, it leaves CISOs and compliance officers with even more questions....more