Whew! 2020 is over and we can start the New Year with hope – a fresh approach to restoring life “as it was before.” It is hard to imagine life before 2019 because no matter what – we have been changed forever....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
DOJ and the SEC each had a great year in FCPA enforcement. But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more
1/6/2021
/ Airbus ,
Bribery ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ethics ,
Goldman Sachs ,
Herbalife ,
Novartis ,
Regulatory Violations ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
DOJ and the SEC have provided unprecedented compliance guidance and information. DOJ has established itself as the preeminent leader in advancing ethics and compliance programs, best practices and innovations. No agency or...more
The Justice Department and regulatory agencies have emphasized the importance of corporate culture and the importance of ethics. As companies approach this important issue, it is important to examine a variety of strategies...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
Watching the compliance industry and advocating for the compliance profession can be frustrating. Corporate boards and senior management know the importance of committing to a culture of compliance. To accomplish that task...more
In the wake of the International Institute of Auditors recent proclamation of a revised and controversial Three Lines of Defense Model, I thought it would be helpful to underscore the importance of the Internal Audit and...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
Last week, Steele Compliance Solutions announced the global rollout of its new “Risk Intelligence Data” platform. As a global leader in ethics and compliance data management technologies, Steele makes a patented addition to...more
The often-used phrase of “tone at the top” is inartful in my view – an organization’s leadership culture is defined much more broadly than the word “tone” implies. A company’s culture extends well beyond senior leadership...more
6/12/2020
/ Blue Bell Creameries ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Ethics ,
Food Contamination ,
Food Manufacturers ,
Food Safety ,
Food Supply ,
Listeria ,
Quality Control Plan ,
White Collar Crimes
Human Resources and Compliance have always had a natural and tight bond, assuming that there is no territorial or in-fighting political disputes. In this new COVID-19 pandemic era, the HR and Compliance partnership is even...more
Under the U.S. Federal Sentencing Guidelines, in order to receive credit for having an effective compliance program, and thereby reduce the fines imposed on the organization, a Board of Directors must be “knowledgeable about...more
A company's commitment to implementing an effective ethics and compliance program must include a reliable internal investigation program. In order to build trust and a speak up culture, an internal investigation program has...more
Like all compliance programs, a company lives or dies based on its ethical culture. A company with a poor culture that operates in a concentrated competitive market has significantly higher antitrust risks than companies...more
I have to admit that it is hard to maintain this blog under the current circumstances. It is hard to ignore the “elephant in the room.” ...more
We all know that economic incentives are critical to promoting performance. Going back to the days of Adam Smith, the U.S. economic growth is the result of a basic motivation – hard work can result in significant...more
Chief compliance officers are heroes. They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more
3/3/2020
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corruption ,
Ethics ,
Internal Controls ,
Leadership ,
Risk Management ,
White Collar Crimes
Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations. Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more
In a comprehensive enforcement action, the Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf for his role in the sales practices misconduct scandal....more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
2/11/2020
/ Anti-Corruption ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Cooperative Compliance Regime ,
Corporate Governance ,
Ethics ,
Internal Controls ,
Policy Management ,
Risk Management ,
Third-Party Risk ,
White Collar Crimes ,
Willful Misconduct
I am reluctant to start off the New Year with a negative comment or posting. But I have a significant concern about the path and current state of ethics and compliance....more
1/24/2020
/ Automation Systems ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Ethics ,
Internal Controls ,
Leadership ,
Risk Management ,
Senior Managers ,
Technology ,
Vendors
As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance. Good compliance means good business – we all know that....more
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more
1/14/2020
/ Analytics ,
Automation Systems ,
Chief Compliance Officers ,
Compliance ,
Cooperative Compliance Regime ,
Corporate Culture ,
Corporate Governance ,
Data Management ,
Department of Justice (DOJ) ,
Ethics ,
Federal Sentencing Guidelines ,
Innovative Technology ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Violations ,
Speak-up Cultures ,
Strategic Planning