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The Continuing Importance of Conflict of Interest Compliance

We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived...more

Measuring Compliance Program Performance and Effectiveness

You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little...more

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review [Audio]

How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

DOJ Updates Evaluation of Corporate Compliance Programs

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

Supply Chain “Audits” and Risk Mitigation

We have seen an explosion in the attention paid to legal, compliance and operational risks companies face in supply chain operations.  Depending on the industry, companies have to address a wide-swath of supply chain risks,...more

The Importance of Compliance Independence

The issue was a professional debate over the reporting relationship between the chief compliance officer (CCO) and the chief legal officer (CLO)/general counsel. After 20 years of debate, CCOs managed to sway the professional...more

SEC Outlines “Effective Cooperation” Standard

The Securities and Exchange Commission is catching up to DOJ.  Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more

The Compliance “Curse” — Learning to Compromise Principles

Compliance lessons are life lessons.  Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal.  Compliance professionals live in the shadow of...more

Episode 332 -- Deep Dive into SEC’s Internal Controls and Cybersecurity Settlement with R&R Donnelly [Audio]

In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. ("RRD") for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more

Episode 331- NAVEX State of Risk and Compliance Programs [Audio]

NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

NAVEX’s Report on the State of Compliance: Positive News with Serious Gaps Noted

NAVEX delivers quality studies and important insights on ethics and compliance topics.  In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

Episode 327 -- Another Look at the Importance of Corporate Culture [Audio]

LRN has issued another important report -- in its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable...more

Episode 326 -- Dottie Schindlinger on Diligent's Report on Board Oversight of Cybersecurity Risks and Performance [Audio]

Dottie Schindlinger is Executive Director of Diligent Institute, the global corporate governance research arm of Diligent - the largest SaaS software company in the Governance, Risk, Compliance (GRC), and ESG space. Diligent...more

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II)

In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture.  LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

Checking In on Caremark Cases in Delaware

Over the last ten years, we have seen a marked shift from the Delaware Chancery Court chipping away at corporate board member liability claims.  In a number of seminal cases involving Boeing airplane crashes (In re the Boeing...more

SEC Finally Issues Climate Change Disclosure Rules

After months and months of deliberations and negotiations, the SEC finally issued its final rules for climate disclosures. The Enhancement and Standardization of Climate-Related Disclosures for Investor (“the final rule”)....more

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

LRN’s latest report was based on a survey of more than 1,400 ethics and compliance professionals, most of whom were employed at organizations with at least 1000 employees in 19 different countries and 26 industries across...more

Top Five Risks Facing Corporate Boards

A Top 5 list should be viewed with suspicion — it is often just a headline grabbing posting with the clear purpose to gain readers’ attention.  In defense, however, it is interesting to compare articles on risk rankings....more

“Person” of the Year: Technology and the Challenges for Ethics and Compliance

I always enjoy retrospective “year in review” postings to start off the new year.  For years, I have sought to identify and capture important compliance trends, typically focused on specific professionals in the compliance...more

Profiles in Effective CEO Leadership

One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations.  To focus on the latter, I have met some...more

Simplicity – the Key to Compliance Persuasion

We all know the adage – Keep it Simple Stupid (“KISS”).   The principle applies to all organizations and underscores an important communications requirement.  The governance landscape has become more complex over the...more

The Evolution of the Compliance Profession

One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

LRN’s 2023 PEI Report: Values and Corporate Culture

LRN’s annual Program Effectiveness Report is chock full of important findings.  Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it)....more

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