CEOs Compliance

News & Analysis as of

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

Top Reasons CEOs Get Sued—and How to Avoid Them

It’s no secret that lawsuits can often be frivolous, and CEOs are not exempt from getting sued. The last thing your company needs is a lawsuit that could have been avoided. Whether filed by a disgruntled employee or the SEC,...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

SEC Sanctions Investment Adviser For Materially False Advertisements

The SEC recently instituted proceedings against a registered investment adviser and its founder, CEO and majority shareholder for allegedly making material misstatements and omissions regarding the amount of assets...more

The 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

Alert: SEC Adopts Final Pay-Ratio Rule

On August 5, 2015, the SEC adopted a final rule to implement Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, often referred to as the pay-ratio provision. The pay-ratio provision mandates...more

The Necessary Ingredient to Compliance Success: Interpersonal Skills

We always bandy the phrase around of “people skills,” or the old trendy phrase of “emotional intelligence.” Hopefully, this posting can create some ideas around new approaches to these old concepts and trendy terminology....more

SEC Pay Ratio Rules — A Recipe for Compliance and Model Disclosure

The SEC recently adopted its final pay ratio disclosure rules. Commencing in early 2018, public companies[1] will have to disclose (i) their CEO's total annual compensation, (ii) the median total annual compensation of all...more

SEC Adopts Pay Ratio Rules

On August 5, 2015, the Securities and Exchange Commission (“SEC”) adopted rules, as directed by Congress in Section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Section 953(b)”), to require...more

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