I am not one to engage in hyperbole. But when it comes to blockchain technology and the implications for our economy, this is going to be the real deal. In the world of ethics and compliance, blockchain has many possible...more
The Justice Department’s Antitrust Division maintains a robust criminal enforcement program fueled by the steady stream of leniency applicants. Since the 1990s, the Antitrust Division has trumpeted a successful leniency...more
7/18/2018
/ Antitrust Division ,
Antitrust Provisions ,
Antitrust Violations ,
Barclays ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ethics ,
Remediation ,
White Collar Crimes
Maybe I am missing something, but everyone is jumping on the culture bandwagon. Regulators like to speak about it; prosecutors like to emphasize it – everyone likes to talk about it as a way to encourage corporate leaders to...more
There are a lot of talented CEOs. Some remarkable leaders, innovators and eloquent spokespeople for their companies. In several recent experiences, I have been befuddled by some CEOs....more
Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more
6/13/2018
/ Bribery ,
Compliance ,
Corruption ,
Enforcement Actions ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Libor ,
Libya ,
Risk Management ,
Third-Party Risk ,
White Collar Crimes
We often hear the compliance refrain on the importance of tone-at-the-top – meaning when the board, the CEO and senior executives demonstrate by communications and by conduct their commitment to a culture of ethics and...more
The compliance profession cannot rest on its achievements and become complacent. There are two significant events that are on the horizon and inevitably will occur....more
A chief compliance officer can only succeed with the support of other important compliance partners. Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the...more
We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more
5/23/2018
/ C-Suite Executives ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Ethics ,
Internal Controls ,
Tone At The Top ,
White Collar Crimes
Corporate commitment to speak up cultures is suffering. The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey contained a critical finding – corporate instances of retaliation against employee...more
5/18/2018
/ Bribery ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Ethics ,
Internal Reporting ,
Ombudsman ,
Retaliation ,
Risk Management ,
Whistleblowers ,
White Collar Crimes
As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives. So, our kids start to speak up...more
We all know the saying – A fish rots from the head. Sometimes a clear and simple statement says it all. The Volkswagen diesel emissions cheating scandal is yet another example of C-Suite, even CEO, misconduct....more
5/16/2018
/ Automotive Industry ,
CEOs ,
Compliance ,
Corporate Misconduct ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Environmental Violations ,
Ethics ,
National Emissions Standards ,
Volkswagen ,
White Collar Crimes ,
Wire Fraud
This week I am posting a five-part series on FCPA compliance issues. While there have been many advances in the anti-corruption ethics and compliance field, there is still more work to do to advance effective strategies for...more
The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more
These are inspiring times for the compliance profession. Looking back on the last ten years, it is amazing to observe the growth and influence of the compliance profession. Many of the original advocates for the compliance...more
Compliance is a dynamic subject and a profession that “never sits still.” Compliance professionals are always developing new ideas, strategies and approaches to solve problems, and increase efficiency and effectiveness. It...more
The Ethics and Compliance Institute recently released the results of its global business ethics survey. The last survey was conducted in 2013 and ECI’s survey provides important and valuable insights into corporate metrics...more
In the last few years, the tension between chief compliance officers and general counsels appears to have subsided. The issue of separating CCOs from legal departments is not as important as it used to be. Why?...more
We always hear about the importance of tone-at-the-top. Corporate leaders are very familiar with how to say the right things about ethics and compliance and the company’s culture. But we all know that words are cheap – it...more
Companies are getting on the bandwagon – corporate culture matters. Business ethics is important. My worry is whether this new acknowledgement is viewed as a short-cut for compliance investment....more
In the business world, answering questions is not the same as the game show Jeopardy. Nor does it require an answer in the form of a question (thank goodness, although that is not a bad strategy). CEOs are used to being put...more
Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more
2/23/2018
/ Banking Sector ,
Banks ,
BSA/AML ,
Compliance ,
Corporate Culture ,
Corruption ,
Enforcement Actions ,
Ethics ,
Financial Institutions ,
Rabobank ,
Settlement ,
US Bank ,
Wells Fargo ,
White Collar Crimes
The ultimate success of a global ethics and compliance program often depends on the ability of local compliance officers to engage business operations in a specific country. ...more
Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs. From my vantage point, the set of challenges can be different depending on the industry. Global...more
An effective ethics and compliance program depends on the Chief Compliance Officer’s authority, independence, and resources. A company’s commitment to a compliance program requires money and employees – there is no question...more