CEOs Compliance

News & Analysis as of

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

Revenge of the Whistle-blower: Possible Consequences of Compliance Failures

In a company with a robust compliance culture, potential whistleblowers can express their concerns without fear of retribution. By contrast, the penalty for a culture that silences whistleblowers just got steeper. Companies...more

External Perception of Your Internal Culture Is a Big Deal: What Uber’s Problems Have Taught Us about Reputation

Ethics and compliance officers might often feel like your company’s corporate culture gets tied into knots, with so many groups imposing demands on your organization’s behavior. But really, a better turn of phrase here...more

Walking the Walk and Talking the Talk – A CEO’s Commitment to Ethics and Compliance

The phrase tone at the top is becoming trite. Compliance professionals use it over and over, and few people explain how to apply the concept. Speakers and webinar presenters always gloss over tone at the top, emphasizing...more

Understanding the Benefits of Benchmarking & How to Do It Successfully

To begin, let’s define “benchmarking.” There is often confusion regarding the difference between benchmarking and assessment. ...the process of benchmarking is a subset of compliance program assessment....more

The Power of Honesty – A Candid Assessment of Your Compliance Program

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

Compliance Expertise Needed on the Board

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

On Leadership – A Simple Message and Asking the Right Questions

Sometimes, as a leader it is important to say something numerous times, to repeat your message so that it will come through loud and clear. For any Chief Executive Officer (CEO) it is incumbent to continually reinforce your...more

When Tone at the Top Is Missing

We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Great Rockers at 50 – The Moody Blues and Being a Great Boss

One of the favorite sobriquet’s I have recently received was from Alison Taylor who called me the ‘rock and roll compliance blogger’. I love to listen to classic rock and enjoy live performances even more. With that moniker...more

Corporate Law and Governance Update - October 2016

New Officer and Director FCA/Stark Exposure - Recent developments may merit a measured briefing to corporate leadership on the potential exposure of health industry officers and directors to financial penalties and other...more

CEO of World Trade Center contractor found guilty of fraud by misstating compliance with Port Authority’s minority- and...

Public entities at the Federal, state, and local levels set aside contracting opportunities, provide preferential price treatment, or otherwise grant favorable treatment to contractors (1) owned by veterans, women,...more

Preparing for GRC in the Decade to Come

What will the world of governance, risk, and compliance look like by 2025? This field is too broad and fast-changing to talk about the far future (and in GRC, 10 years definitely is “the far future”) with any...more

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

CCOs: Living in the Land of False Promises

We all have heard the scenario involving a compliance professional. A new CCO joins a company with promises from the board, the CEO and senior executives of cooperation, compensation and support for a robust independent...more

Honest Assessment of the CCO-CEO Relationship

One very accurate indicator of a compliance program is the relationship between the CEO and the Chief Compliance Officer. If a CCO is repeatedly making excuses for a CEO who does not devote enough time to compliance, you can...more

A Lesson in Compliance: Part II

The following is an interview with Richard Bistrong and Alessia Lamonaca, Program Marketing Specialist at Resolver Inc. In “A Lesson in Compliance with Richard Bistrong: Part I“, Richard discussed the thought process...more

Defining Compliance 2.0: The CCO (Part 3 of 5)

These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the...more

Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance

Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement....more

Dodd-Frank Executive Compensation Update: SEC Adopts CEO Pay Ratio Disclosure Rules

The Securities and Exchange Commission (SEC) recently adopted final rules implementing one of the last four remaining executive compensation requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. ...more

The Dalton Gang’s Last Stand and What is a Conflict of Interest?

On this day in 1982, the fabled Dalton Gang rode into Coffeyville, Kansas, supremely confident in its ability to simultaneously rob two banks in the town. When the dust settled, four of the five gang members lay dead. The...more

Creating Trust to Effect Compliance Change

One of the ongoing battles for any Chief Compliance Officer (CCO) or compliance practitioner is that the business folks usually view compliance as the Land of No; most often populated by Dr. No him or herself. You will have...more

New Volcker Rule FAQs: Market Making and CEO Certifications

Two new Volcker Rule FAQs have been issued. One FAQ addresses a bank’s market making activities. Amongst other things, the FAQ affirms that for purposes of meeting the final rule’s exemption for market-making, a...more

Two Essential Requirements for Tone At the Top

Everyone likes to give advice on the importance of tone at the top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue....more

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