For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within an organization and take on the firm’s...more
The Staff of the SEC’s Division of Investment Management has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more
The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. Groucho Marx - We are all taught the importance of honesty. But there are very different aspects to this otherwise simple...more
This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more
Resources to help you engage your board of directors in the success of your ethics and compliance program. A successful board engagement strategy can help ethics and compliance professionals gain significant program...more