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
A chief compliance officer needs to be independent and have adequate authority within the organization. But do not get confused by the concept of independence. Compliance depends on collaborative relationships with other...more
Let’s face it – corporate boards are not adept at overseeing a company’s compliance program. In the absence of a board member who has prior compliance expertise, corporate boards either ignore or struggle to fulfill their...more
Companies have to embrace a holistic management approach to their internal controls. In the corporate governance world, a new approach is needed to develop a more rational and consistent method for managing your company’s...more
Companies do not operate in a vacuum. As we know, companies are part of our social fabric and are subject to the same influences as our communities, politics and families....more
3/1/2018
/ Anti-Harassment Policies ,
Civil Rights Act ,
Compliance ,
Corporate Culture ,
Employee Training ,
Employer Liability Issues ,
Employment Policies ,
Equal Employment Opportunity Commission (EEOC) ,
Harassment ,
Hostile Environment ,
Risk Management ,
Sexual Harassment ,
Title VII ,
Tone At The Top
If you want to learn and read about managing third-party risks, you will have no trouble finding articles, white papers, webinars and more available to you on the Internet. And for good reason....more
Cybersecurity compliance, like the compliance profession, is rapidly growing. The forces pushing cyber compliance are two-fold: the ever-increasing and changing nature of cyber threats and harms, and the logical application...more
2/22/2018
/ Compliance ,
Corporate Management ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Hackers ,
Internet of Things ,
Malware ,
Phishing Scams ,
Popular ,
Risk Management
The nightmare scenario for corporate boards and senior executives revolves around the impact of a major data breach. We have seen this first hand with Equifax, Anthem Healthcare, and Target, as prime examples. In the Equifax...more
Wells Fargo’s ability to grow its business is on hold for a year while it designs and implements a remediation program to address deficiencies in its board governance, risk management and compliance program. ...more
2/14/2018
/ Bank Accounts ,
Banking Sector ,
Compliance ,
Consumer Financial Products ,
Corporate Culture ,
Corporate Governance ,
Cross-Selling ,
Enforcement Actions ,
Federal Reserve ,
Internal Controls ,
Remediation ,
Risk Management ,
Wells Fargo
In an extraordinary action, with significant ramifications for the financial industry, the Federal Reserve recently announced a series of enforcement actions against Wells Fargo....more
2/13/2018
/ Banking Sector ,
Board of Directors ,
Compliance ,
Consent Order ,
Corporate Culture ,
Corporate Governance ,
Cross-Selling ,
Employee Incentive Plans ,
Enforcement Actions ,
Federal Reserve ,
Remediation ,
Risk Management ,
Wells Fargo
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
Given the turbulent times we live in, it is refreshing when we hear a corporate leader explain the importance of trust as a corporate value. Marc Benioff is the CEO at Salesforce who is aggressively pushing his company to...more
The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions. (Here). The NYDFS has filled a vacuum created by the failure of the federal government to act in this...more
1/31/2018
/ Banking Sector ,
Chief Information Security Officer (CISO) ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Financial Institutions ,
Hackers ,
NYDFS ,
Personally Identifiable Information ,
Popular ,
Risk Management ,
Third-Party Risk
Cybersecurity law is a patchwork of global statutes and regulations. Unfortunately, Congress has failed to act in this area, leaving the EU and US States to “lead.” As a result, companies are often required to follow the...more
Global companies are getting compliance overload, especially when it comes to third party risks. As we have seen over the years, third-party risk management involves significant risks on anti-corruption, AML, fraud,...more
When you survey business leaders on significant risks, they invariably cite cybersecurity as number one and anti-corruption as number two. For global businesses, this makes total sense. Cyber-crime damage is estimated to...more
1/24/2018
/ Anti-Corruption ,
Chief Information Security Officer (CISO) ,
Compliance ,
Corruption ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Information Technology ,
Popular ,
Risk Management
Companies are correctly focused on cybersecurity risks. Notwithstanding this focus, companies are struggling with how to respond to threats and risks. Cybersecurity threats are quickly evolving – akin to the time when...more
The chief compliance officer is at an important professional juncture – 2018 is an important year for the profession. In this era of growth, and after corporate tax relief, companies have an opportunity to invest increased...more
It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more
1/19/2018
/ Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Compliance ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Regulatory Agenda ,
Regulatory Oversight ,
Risk Management ,
Suspicious Activity Reports (SARs)
Compliance officers are a much more collaborative group of professionals than lawyers. Compliance officers share information with colleagues about compliance experiences, best practices and strategies. The compliance...more
We all enjoy citing government sources for guidance on an effective ethics and compliance program. Whether it is the United States Sentencing Guidelines, the Justice Department’s and SEC’s FCPA Guidance, Health and Human...more
When you look back on the rise of the ethics and compliance profession, you cannot ignore the history of accomplishments. It is easy to minimize these accomplishments as a reaction to the government’s aggressive FCPA...more
1/9/2018
/ Audits ,
Board of Directors ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Corruption ,
Distributors ,
Ethics ,
Risk Assessment ,
Risk Management ,
Third-Party Agents ,
White Collar Crimes
A basic truism is – ethics and compliance reinforce each other. An ethical culture is an effective control against violations of law and a company’s code of conduct. Conversely, legal compliance promotes a company’s...more