Chief compliance officers have to be honest with themselves. While I am optimistic about the growing importance of the compliance function, I remain concerned that CEOs and senior management are slowly strangling ethics and...more
Chief compliance officers have to throw out their template for charts, diagrams and data that they use to report to the Audit/Compliance Committee and start over. Slick and colorful charts and diagrams are great but CCOs are...more
People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more
It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more
Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more
Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance....more
Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to...more
At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more
A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.”...more
As chief compliance officers realize the importance of criminal antitrust compliance, it is important to identify the real risk factors. All too often we get lost in the mumbo-jumbo (a technical term, I know) of compliance,...more
We often read articles and blog postings about anti-corruption, anti-money laundering, export controls and sanctions compliance issues. The focus on these topics is justified. However, there is one glaring omission –...more
Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party.
Rather than reject the third party, a CCO convinces him or...more
Ethical culture is the flavor of the year these days. We are seeing more postings and articles about the importance of ethical culture, and even pushing the idea of measuring and monitoring culture....more
Chief compliance officers are the rising stars in the corporate governance world. However, CCOs have to avoid complacency. CCOs have a lot more to accomplish — it is almost as if the profession has put its collective foot...more
Sometimes my references to Seinfeld episodes or Curb Your Enthusiasm vignettes do not work or can charitably be characterized as a little off. Nonetheless, I press on....more
Compliance practitioners are opportunists. They have to look for openings in the corporate resource world to build partnerships with related functions. To put it another way, they are purveyors of compliance thinking – they...more
One of several difficult compliance questions facing companies revolves around reporting of employee concerns. If the number of complaints coming in on a company hotline goes down over time, is corporate misconduct going down...more
Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more
It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry....more
Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’...more
The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more
If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say?
Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more
We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do.
With increasing emphasis and understanding of the...more
Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more
This posting is not a “pie in the sky” outline of compliance in the future, when technology works seamlessly with compliance functions. My focus today is on what is happening now in the compliance world when it comes to...more