You can draft and design the best ethics and compliance program – and then fail. You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each...more
Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG....more
There are a lot of so-called “dirty secrets” in the corporate governance world. Not the tawdry kind that appear to follow controversial politicians – I mean in the world of internal controls....more
It is easy to get lost in ESG. Focus is the key. Leadership has to define the ESG strategy. A designated officer has to lead implementation....more
Perhaps I am little bit behind. That would be nothing new – but we are getting to the point where we no longer need to spell out ESG. Everyone knows what it means – directors, officers, employees, investors, shareholders...more
A good lawyer knows the law; a clever one takes the judge to lunch. — Mark Twain -
Lawyers get a bad rap – not just as the subject of lawyer jokes. (This is not an invitation to recite lawyer jokes)....more
The Ethics and Compliance Initiative is a terrific organization that provides important ethics and compliance insights and leadership. Starting in 1994, ECI has conducted a longitudinal, cross-section study of workplace...more
The COVID-19 pandemic uncovered the fragility of business operations – within the space of weeks, companies were forced to adjust to distribution channel and supply chain disruptions, workplace closings, and a virtual...more
The success of a compliance program depends on a number of factors. Perhaps one of the most important factors is the strength of the relationship between compliance professionals and business. Compliance depends on business...more
Chief compliance officers (CCOs) are talented professionals. As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation. CCOs focus on legal and compliance risks...more
3/17/2021
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Risk Management ,
Subject Matter Experts (SMEs) ,
White Collar Crimes
Corporate boards will continue to face higher risks of liability. As the last bastion of legal privilege and protection, the wall of protection is crumbling bit by bit. Eventually, corporate stakeholders will demand that...more
Corporate governance sometimes is the subject of “fads,” or initiatives that gain traction with dubious evidence-based justifications. Sometimes companies engage new theories or strategies because they “sound good,” or give...more
I have always played down the issue of CCO liability and prosecutions. I dismiss these concerns often because the reporting of CCO prosecutions are usually exaggerated and meant to instill fear in compliance professionals. ...more
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
To start the New Year, it is a good idea to review the trends in the role and status of Chief Compliance Officers. As we witness the continuing growth in stature of the CCO, we need to exercise caution. Some troubling...more
In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more
If ever there was a year that challenged corporate leaders on their commitment to business ethics, 2020 was the year. The number of difficult issues facing corporate leaders were challenging and ran the gamut – from health...more
The United States continues to lag in corporate board diversity. Many corporate boards are dominated by white males. Progress on this issue has been slow....more
Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance...more
Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman...more
If you speak to members of a corporate board and the C-Suite and you ask them if the company has a strong ethical culture, we all know what they will say – “Of course, we do. We have a strong commitment to our Code of...more
Boeing is the new poster child for corporate governance failures and misconduct. Move over Wells Fargo, General Motors, Volkswagen, Novartis, Siemens and Wal-Mart, and make room for Boeing. Like General Motors and its...more
10/2/2020
/ Airplane Accidents ,
Aviation Industry ,
Boeing ,
Compliance ,
Congressional Committees ,
Corporate Governance ,
Corporate Misconduct ,
Corruption ,
Critical Infrastructure Sectors ,
Equipment Failure ,
Federal Aviation Administration (FAA) ,
Regulatory Violations ,
Shareholder Litigation ,
Transparency
Corporate governance and compliance is not as hard as everyone tries to make it. Much of management theory, risk management, and theories surrounding corporate operations is intuitive.
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Corporate board members face increasing risks. Federal prosecutors are watching their behavior when corporate malfeasance occurs. Regulators focus on the important issue of board governance. Shareholders are ready to file...more
Corporate boards face serious challenges – business disruption from the pandemic and a slowing global economy. Directors have to focus on these two issues for at least the next 12 months....more