At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional...more
Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance....more
At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more
There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more
9/7/2017
/ Bribery ,
Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Due Diligence ,
Ethics ,
FCPA Guidance ,
Risk Mitigation ,
Third-Party Risk ,
White Collar Crimes
We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more
9/6/2017
/ Automotive Industry ,
Bank Accounts ,
Banking Sector ,
Beneficial Owner ,
Bribery ,
Compliance ,
Corruption ,
Cross-Selling ,
Ethics ,
Financial Fraud ,
General Motors ,
Internal Controls ,
National Emissions Standards ,
Product Defects ,
Telecommunications ,
VimpelCom ,
Volkswagen ,
Wells Fargo ,
Whistleblowers ,
White Collar Crimes
A corporate entity is like its own community – it has a culture, a set of values and principles that form the foundation for the company’s operations, and an overall purpose. The interesting factor that has to be identified,...more
Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party.
Rather than reject the third party, a CCO convinces him or...more
Ethical culture is the flavor of the year these days. We are seeing more postings and articles about the importance of ethical culture, and even pushing the idea of measuring and monitoring culture....more
Sometimes my references to Seinfeld episodes or Curb Your Enthusiasm vignettes do not work or can charitably be characterized as a little off. Nonetheless, I press on....more
One of several difficult compliance questions facing companies revolves around reporting of employee concerns. If the number of complaints coming in on a company hotline goes down over time, is corporate misconduct going down...more
Compliance practitioners divide their commentary and insights into two general categories – ethical culture and compliance controls. It is easy to divide compliance issues into these two categories. Ethical culture articles...more
Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more
For some reason, I have always believed that picking successful stocks should not be very difficult. Unfortunately, my record in the stock market does not back up my self-assessment.
On the other hand, when it comes to...more
It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry....more
Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’...more
Honesty is the best policy – when there is money in it. – Mark Twain -
Compliance professionals encounter a diverse range of corporate personalities in their work. To be sure, compliance officers have to rely on their...more
The business headlines are filled with the latest corporate scandal – Uber’s defective culture, CEO misconduct and reprehensible comments by supervising board members. Uber is just one of several significant companies caught...more
The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more
If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say?
Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more
We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do.
With increasing emphasis and understanding of the...more
Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more
A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he...more
With an increasing focus on the value of an ethical culture, I have been reading more about chief ethics officers, the separation of ethics and compliance, and the traveling ethics officer who meets with employees to discuss...more
Those who regularly read my blog have heard me often cite the need for the compliance profession to adopt professional standards. With the rise of the profession, and the expectations placed on the shoulders of compliance...more
Deputy Attorney General Rosenstein’s appointment of Special Counsel Robert Mueller last week was a blockbuster development in the investigation of the administration....more
5/23/2017
/ Corruption ,
Department of Justice (DOJ) ,
Donald Trump ,
Ethics ,
Ethics Breach ,
FBI ,
Government Investigations ,
Independent Counsel ,
Russia ,
Trump Administration ,
White Collar Crimes