This is likely to be a politically incorrect posting. I hope I do not offend too many people, especially those new data privacy professionals.
As kids, we were always excited when an ice cream truck visited our...more
Compliance professionals are implementing their own monitoring and auditing strategies. Internal audit does not have the resources nor the time to assume responsibility for this function. If possible, internal audit may...more
Chief compliance officers have a hard job. CCOs know that fact and them fully embrace the challenges of their positions. At the same time, CCOs have extraordinary expectations placed on their shoulders – they are rarely...more
This may be another in my series of profound grasps of the obvious – the compliance profession, research, technology and innovation are rapidly improving. We all hear about innovative compliance approaches, new use of data...more
The Justice Potter Stewart phrase, “You know it when you see it,” applies to life issues and even compliance. Global companies struggle with program design, allocation of resources (e.g. human resources and money/assets),...more
People are good at convincing themselves that everything is okay, despite troubling indications. Sometimes it is easier to ignore warning signs than to face the harsh reality....more
We all like to believe in straight-forward and consistent trends and developments. For example, compliance programs are improving, budgets are increasing, and CCOs are embracing new technologies. Everything is just rosy...more
While I hate to start out a posting with such “mumbo jumbo” terms, I had to come up with short hand descriptions of some otherwise fairly complex and robust topics under the new DOJ Guidance....more
5/7/2019
/ Best Practices ,
Chief Compliance Officers ,
Corporate Misconduct ,
Corporate Officers ,
Department of Justice (DOJ) ,
Ethics ,
Human Resources Professionals ,
New Guidance ,
Performance Incentives ,
Policies and Procedures ,
Professional Disciplinary Actions ,
Senior Managers
Part 1 of the Corporate Compliance Guidance addresses the following elements of a well-designed compliance program: risk assessment, policies and procedures, training and communications, confidential reporting structure and...more
5/3/2019
/ Best Practices ,
Chief Compliance Officers ,
Corporate Counsel ,
Corporate Culture ,
Corporate Officers ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Ethics ,
New Guidance ,
Policies and Procedures ,
Risk Assessment ,
Senior Managers
In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs....more
5/2/2019
/ Best Practices ,
Chief Compliance Officers ,
Corporate Counsel ,
Corporate Culture ,
Corporate Officers ,
Department of Justice (DOJ) ,
Directors ,
Ethics ,
New Guidance ,
Policies and Procedures ,
Risk Assessment ,
Senior Managers
The Treasury Department’s Office of Foreign Asset Control (OFAC”) continues its enforcement run. In a recent case against Haverly Systems, Inc., OFAC sent an important reminder to US companies about compliance with the...more
There is nothing training cannot do. Nothing is above its reach. It can turn bad morals to good; it can destroy bad principles and recreate good ones; it can lift men to ‘angel ship. – Mark Twain...more
A basic compliance program control, which is often overlooked (or assumed to exist), is the requirement that a chief compliance officer and/or chief legal officer have the authority to stop a specific contract or business...more
A fundamental requirement for an effective ethics and compliance program is that it is supported by “adequate resources.” This does not mean a bare minimum requirement; nor is this requirement satisfied by flat-lining a...more
Over the last twenty years, we have seen a fundamental re-orientation in compliance. I would argue that as the compliance profession has expanded and taken on greater space and responsibility in the corporate governance...more
Maybe I am getting slow in my old age – or just maybe I am losing a step or two. We all face that inevitable question – and perhaps, for me, it is best illustrated when I come up with yet another in my series of profound...more
The beauty of an effective ethics and compliance program is captured in the well-known phrase that it is worth much more than the sum of its parts....more
Compliance officers have enough challenges. Most compliance officers, if you ask them, will candidly admit they are constantly putting out fires. It is just part of the profession and comes with the territory....more
We all enjoy citing Supreme Court Justice Potter Stewart’s famous description relating to obscene materials, “I know it when I see it.”...more
Chief compliance officers face a mountain of tasks – it is easy to get overwhelmed. Add to the mix the fact that CCOs are under extraordinary pressure to “prevent and detect” potential violations of the company’s code and...more
Compliance officers have a difficult job.
So why are so many people interested in joining the profession?
At bottom, compliance professionals are inspirational professionals and inspired by their mission. Compliance...more
Chief financial officers are powerful players in the corporate governance landscape. CFOs play a critical role in the management and oversight of the company’s internal accounting controls. Sarbanes-Oxley lifted the...more
10/4/2018
/ CFOs ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Corruption ,
Financial Reporting ,
Internal Audit Functions ,
Internal Controls ,
Risk Management ,
Sarbanes-Oxley ,
White Collar Crimes
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more
Congratulations on your new position as the chief compliance officer. You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package. ...more
An increasing number of chief compliance officers report directly on a monthly basis to the Chief Executive Officer. As the compliance profession has earned independence and empowerment, CCOs are now part of the C-Suite and...more