Compliance Tip of the Day: Why Engage in Pre-acquisition Due Diligence
Compliance Tip of the Day: Bringing Predictive Analytics into Your Compliance Regime
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 2 - Risk Assessment
FCPA Compliance Report: Fraud Risk Management - Insights and Experiences with Peter Schablik
#Risk New York Speaker Series – Inside Behavioral Insights: Tom Hardin on Compliance at #RiskNYC
Compliance Tip of the Day: COSO Framework
#Risk New York Speaker Series: Exploring AI Risks in Compliance with Gwen Hassan
Healthcare Enterprise Risk Management
Compliance Tip of the Day: Assessing Internal Controls in International Operations
Managing Sanctions Compliance
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
In this new season of Adventures in Compliance, host Tom Fox takes a deep dive into the Sherlock Holmes novels. Throughout this season, Tom will delve into each novel in a four-part series. The four novels we will consider...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
In the realm of auditors intersecting compliance and fraud risk audits, a fierce battle of perspectives rages on. Compliance professionals yearn for a bigger role, a seat at the table to tackle potential compliance...more
Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives. These steps are not just suggestions nor items that can be prioritized...more
I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends. It is a perspective that gives us all the opportunity to identify important trends and to set an agenda for the...more
The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more
Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations. An internal...more
On June 1, 2020, the Criminal Division of the US Department of Justice (“DOJ”) released an updated guidance document for white-collar prosecutors on the evaluation of corporate compliance programs....more
OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs....more
This is my favorite topic. New trends come and go in the compliance field, while effective solutions and strategies slowly but surely take hold. Eventually, an effective compliance practice or strategy becomes a “best...more
Several years ago (or in the recent past as some would say), pre-acquisition due diligence was a major compliance focus for global companies that grew through aggressive merger and acquisition strategies. ...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
As the first-ever Compliance Counsel Expert at the United States Department of Justice (DOJ), Hui Chen served as exclusive consultant to the Fraud Section’s white-collar crime federal prosecutors. She reviewed corporate...more
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
What your culture is today? You should consider what you value in terms of six key areas: dominant characteristics; organizational leadership; management of employees; the glue that holds the organization together; strategic...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
The 2017 SCCE Compliance and Ethics Institute (CEI) is now in the books. Once again, the organization had record setting attendance with over 1,800 attendees from some 41 different countries. During the event, I had the...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
This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more
It was like a bolt out of the blue – United Airlines’ CEO and two senior executives hastily announced their resignation as a result of their involvement in a bribery scandal with the New York Port Authority....more