On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more
11/10/2021
/ Biden Administration ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Policy Statement ,
Prosecutorial Discretion ,
White Collar Crimes
If you follow my blog, you know that I am passionate about the compliance profession. Chief compliance officers have unique talents, expertise and leadership qualities. CCOs are committed ethics warriors. No one else can...more
Chief compliance officers are creative professionals. This is one of many areas of expertise. But when it comes to corporate politics, many CCOs know how to package and promote their mission....more
Chief compliance officers can occasionally suffer from a “complex” (akin to the Jungian one). CCOs and their priorities are often pushed aside in favor of “more important” corporate initiatives. CCOs are used to fighting...more
9/21/2021
/ Business Plans ,
Business Strategies ,
Capital Investments ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Ethics ,
Publicly-Traded Companies ,
Sustainability
When I was a federal prosecutor and investigating corporations for misconduct, I imagined a well-oiled machine with vast resources, capable of overwhelming government prosecutors and law enforcement agents with lawyers,...more
Corporate leaders and executives like to mouth the words surrounding corporate culture. It is part of the code they all use with each other. Few of them, however, really know what the word means or even dare to understand...more
Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry. Compliance...more
Ethics and compliance programs face a rapidly approaching crossroads. Technology and data have created significant pressure on CCOs to harness innovation. This is a major opportunity for improvement but it also creates real...more
While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more
The culture bandwagon is picking up steam. Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations....more
We always read about the superstar CEO. The company’s leader who is paid millions and is the rock star of business success. Board members, shareholders and stakeholders support the leader because he/she has brought...more
Sometimes compliance issues are simple. Most times they are nuanced. This is a simple issue but it carries with it a significant message. So here goes – where is the CCO’s office?...more
We all know (and repeat every day) that corporate cultures reflect social trends and pressures. Companies face extraordinary political and social pressures, and this translates into its corporate workforce....more
Everyone is now on the culture bandwagon. For those of us pushing the issue over the last decade, welcome aboard to everyone. But once you join, the work is only beginning. ...more
While billionaires continue to trumpet their excess and competitive desires to fly into space, they may want to take a look around before launching themselves on the next rocket to the edge of space for a ten-minute flight....more
LRN’s annual Ethics and Compliance Program Effectiveness Report is an important yearly event. The report is often filled with important trends and observations. For compliance officers, there is always important trends and...more
NAVEX Global produces a number of important compliance program reports. NAVEX Global always has played an important thought-leadership role in the ethics and compliance field....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
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
The FCPA Guidance issued by the Justice Department and the SEC says it best – “The truest measure of an effective compliance program is how it responds to misconduct.” ...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 Biden Administration has a lot on its plate – that is obvious. Tackling the COVID-19 pandemic and restoring economic growth is one of the most difficult challenges ever facing our country....more
2/16/2021
/ Biden Administration ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Guidance ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Reform ,
White Collar Crimes
Boeing’s settlement with DOJ raises more questions than answers. While I understand that a criminal case against Boeing requires DOJ to identify one or more individuals who have committed a crime that can be fairly...more
2/4/2021
/ Aircraft Equipment ,
Airplane Accidents ,
Boeing ,
Compliance ,
Corporate Culture ,
Corporate Monitoring ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Equipment Failure ,
Ethics ,
Respondeat Superior ,
Safety Violations
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
1/27/2021
/ Bribery ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corruption ,
Deutsche Bank ,
Enforcement Actions ,
Ethics ,
Failure to Comply ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Controls ,
Spoofing ,
White Collar Crimes