It is good to be an optimist. I am sure that optimistic people are happier, more loving and tend to live longer. All of this rings true.
But not everyone is an angel, and not everyone at your company is a “good...more
Compliance officers face plenty of challenges. The list of close allies always includes the General Counsel, Internal Audit, Human Resources and Procurement officials. In two recent surveys, CCOs reported that they do not...more
If you can’t explain it to a six-year-old, you don’t understand it yourself. — Albert Einstein -
Compliance professionals are in a heady state these days. Their stock is rising; they are gaining influence and authority,...more
Consider this posting a warning to everyone in the corporate governance field. I am not known for being a chicken little and screaming “the sky is falling, the sky is falling.” I tend to be a realist when it comes to politics...more
6/4/2015
/ Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Ethics ,
Financial Regulatory Reform ,
Foreign Corrupt Practices Act (FCPA) ,
Legislative Agendas ,
Regulatory Agenda ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC)
I have to confess that there is a part of me that was skeptical about a new survey released last week finding that banks and other financial institutions have not embraced a culture of integrity. Indeed, the survey found...more
There is no question that the compliance profession is on the rise. My colleague, Donna Boehme and I, frequently advocate on behalf of the compliance profession.
With the rise of the CCO in corporate governance...more
The government is on a public relation campaign. Department of Justice and SEC officials have been making the rounds and giving important speeches on criminal prosecutions, cooperation and voluntary disclosure and ethics and...more
You can add this blog posting to my tagged category – “profound grasps of the obvious.” If you are brave and willing to succumb to yet another in this series, please read on.
Much has been written about how to conduct...more
The old maxim – “Justice delayed is justice denied” – is a powerful statement relating to our criminal justice system. A subject of a criminal investigation – corporate or individual — undergoes enormous stress from a...more
In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate operations, and are aimed at...more
Chief Compliance Officers carry a lot of weight on their shoulders. Some days, I am sure, they have trouble getting up and soldiering on to tackle the next challenge....more
There is something in a name. More people in the compliance industry, when referring to third-party due diligence, are labeling it “Third Party Risk Management.” I like it because it is more accurate....more
If only the New England Patriots had an Anti-Bribery and Anti-Corruption program, “Deflategate” might never have entered America’s vocabulary. The long-running saga re-entered the media this past week with the release of the...more
The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources. In the anti-corruption and sanctions compliance arenas,...more
Everyone likes to talk. For most people, it is hard to listen. Chief Compliance Officers have to be proficient at both, especially listening. I have often criticized CCOs who engage in Happy Talk when reporting their boards....more
It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence system that screens at renewal of a third-party relationship, monitors third-party activity and...more
I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating...more
Third Party questionnaires are a standard part of any due diligence process. They are emailed to the potential third-party business partner, filled out and sent back, or the third-party enters the information through an...more
One of many pet peeves I have in the compliance space is the lack of creativity in compliance program measurement. Chief Compliance Officers have to take a fresh approach to this issue....more
There are two important reasons for documenting a compliance program.
First, a compliance record is valuable to a company’s compliance team as a reference to specific actions taken by compliance professionals and...more
We all have our favorite episodes and scenes from the Seinfeld series. As we grow older, we like to reference them more and more – maybe because it reminds us of your “youth” (looking back, my 30s were certainly younger than...more
Everyone knows the mantra – yes, we need tone at the top, but we also need tone in the middle and tone at the bottom.
Every aspect of this statement, however, requires more work than everyone thinks. Tone at the top is...more
The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx -
Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more
The compliance profession continues to rise in importance. Companies are paying more attention to corporate culture and devoting resources to enhance existing compliance operations. This approach is reinforced with each week...more
Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more