There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more
We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent...more
Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations...more
Happy April Fool’s Day! Could you ever imagine coming to work one day and realizing that you have “finished” your ethics and compliance program? There is nothing left to do. You can go home. Ohhhh, if only it was so....more
One very accurate indicator of a compliance program is the relationship between the CEO and the Chief Compliance Officer. If a CCO is repeatedly making excuses for a CEO who does not devote enough time to compliance, you can...more
As the compliance profession grows, so to the need for valuable writing and scholarship, particularly from authors whothemselves have specific compliance experience and offer practical solutions. Kristy Grant-Hart recently...more
There are many important predictors of corporate culture. Everyone laments the difficult in measuring a company’s culture. There are a few issues, however, that may be inconvertible as a predictor of a corporate culture....more
The compliance profession continues to grow at a fast clip. Hefty DOJ and SEC fines and criminal penalties have prodded companies to embrace the concept of compliance, and rely on compliance officers to keep their companies...more
Chief compliance officers and senior executives wrestle with strategies to spread and embed important compliance messages. A CEO and senior executives can spread a compliance message but they are always battling competing...more
Some things go together. Chocolate chip cookies and milk, Hepburn and Tracy, Lewis and Martin (I know, I am showing my age, but you get the point), and many other favorite combinations. So, you get the point – in the world of...more
Happiness is when what you think, what you say, and what you do are in harmony – Mahatma Gandhi
Happiness is an elusive concept – for some. For others who may be more enlightened or lived for years, happiness is a...more
There has been a lot written about CCOs fearing prosecution for compliance failures. Not to say there is no risk, but the truth lies really in the middle. From my perspective, there is too much fear-mongering around this...more
For years, cyber security has been the province of IT specialist and technicians. Those days are long gone. If you ask a Board of Directors to identify a company’s most significant risk – cyber security is tops....more
The New Year brings new promise for compliance professionals.
I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who...more
As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges....more
Just when you thought things could not get any weirder, along comes the New York Department of Financial Services and proposes a new regulation that sets forth minimum requirements for anti-money laundering transaction...more
Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball and...more
DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance but I would not characterize this year as limited to third party due...more
These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure.
We now have debates over the...more
Do the right thing. It will gratify some people and astonish the rest. – Mark Twain
We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who...more
A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more
Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement....more
Complacency in compliance is a cancer on a company’s culture. Woody Allen said it best in Annie Hall: A [compliance program] relationship, I think, is like a shark. You know? It has to constantly move forward or it dies. And...more
Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer.
A company without a corporate culture of ethics and...more
“It is Time” – Rafiki, The Lion King
Corporate scandals continue to rack up – I am not just blowing smoke on this fact. Corporate boards are under greater scrutiny but the hardest place to bring reform is the corporate...more