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
Rochester Drug Co-Operative, Inc. (“RDC”), one of the 10 largest pharmaceutical distributors in the United States, was recently charged along with its former Chief Executive Officer and former Chief Compliance Officer, for...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
There are many ways for a Chief Compliance Officer (CCO) to exercise leadership in not only the compliance function but also across the many disciplines in which compliance impacts in any corporation. In this Sunday’s New...more