Chief Compliance Officers

News & Analysis as of

Gifts, Travel And Entertainment Under The FCPA – Part I

One of the first thing that many companies will try to put in place is a gifts, entertainment and travel policy when looking at an overall compliance program. I find the reality to be that not only is this one of the more...more

Nursery Rhymes, A Chinese Proverb, The HP FCPA Enforcement And The Myth Of The Rogue Employee

As my friend and colleague Jay Rosen is want to remind us, he continually learns much about compliance and ethics from his Kindergarten-aged daughters. I submit that you need only look to children’s nursery rhymes in the...more

Health Law Wire: $85 Million settlement for first half of Halifax Qui Tam case - OIG Dan Levinson says Management failed to listen...

One of the largest settlements, if approved by the Court, is a result of compensation and incentive programs to physicians who were “employed” at Halifax Hospital in Daytona Beach, Florida. The Halifax lawsuit was filed in...more

Anti-Corruption Digest - April 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Efficient, Nimble, Defensible: More Benefits of Using Short Form Compliance Training

In our first post on burst learning, we covered five key benefits of using burst learning, an approach to ethics and compliance training that utilizes engaging five-to seven-minute products to accomplish any number of an...more

Post Traumatic Settlement Disorder

The rigor and stress of an extensive corporate internal investigation is over. You’ve helped your client determine the scope of wrong-doing, take actions against wrong-doers, calculate the damages/amount of the fraud, fix...more

Tales From The Crypt - Rule No. 7 - Actions Speak Louder Than Words

Ed. Note-I inadvertently ran Tale From The Crypt, Rule No. 8 out of order, so today we present Rule No. 7, which reminds us that Mom was right, actions do speak louder than words... This Tale from our Crypt reminds us...more

Compliance Matters: We interrupt our regularly scheduled programming…

While we strive to bring you the latest regulatory matters that we believe you will find important for compliance purposes, we would like to take a moment to bring you information that may be just as valuable....more

Mickey Rooney And The 90 Cent Solution

We begin today with a word on the death of Mickey Rooney. Rooney’s career, spanning nearly 90 years was certainly was from a different era. He was short of stature and long in his number of marriages but as Bob Lefsetz noted...more

Ketchum Shares Bon Mots with BD Industry at SIFMA Meeting

At this week’s Annual SIFMA Law and Compliance meeting, FINRA CEO Rick Ketchum provided a number of candid and pointed comments in a wide-ranging and no-holds-barred interview conducted by long-time senior compliance official...more

The Battle Of Shiloh, Corruption In Ukraine And Things To Come

On this day 126 years ago the two-day battle of Shiloh ended. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely...more

Do Compliance Professionals Have To Be Lawyers?

As compliance professionals enjoy the rise of their profession, lawyers are sensing a decline in importance. I am hearing from compliance professionals a new and disturbing trend – companies are requiring compliance...more

Dodd-Frank Compliance in a Nutshell

Here are some important Dodd-Frank rules that you need to keep in mind if you are neither a Swap Dealer nor a Major Swap Participant ("Non-SD/MSP"). Clearing - General Rule. Dodd-Frank requires all swaps listed...more

CCO’s Be Careful What You Ask For — You Just May Have It

The old adage has taken hold in the compliance field – “Be careful what you ask for, you just may get it.” Compliance professionals are finally getting the respect they deserve. They still have a long way to go. ...more

Anti-Corruption Digest - March 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Tales From The Crypt - Rule 6: Never Mix Business With Pleasure

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

Encouraging Communication Of Employee Concerns

One of the hardest issues for compliance professionals is encouraging employees to raise concerns about ethics and compliance issues. It has become even more difficult when the government establishes whistleblower programs...more

Common Mistakes, Problems And Concerns Companies Face During Implementation And Maintenance Of Corporate Compliance Programs

An effective corporate compliance program is an essential component of internal controls for uncovering and preventing ethical lapses and criminal violations and smart companies are prudently adopting these programs. However,...more

Keeping Compliance Focus On Risky Interactions

People who consistently miss the point are frustrating. Focus is an important discipline. Whatever you do in life, the ability to focus is critical....more

Best Practices For Anti-Corruption Compliance Programs – A Moving Target

The Justice Department and the SEC have pushed extraordinary changes in the field of anti-corruption compliance. If one looks back five years ago and compares the so-called best-practices from 2008 and compares them to...more

FINRA Sanctions Firm And Compliance Officer For AML Violations

This past February, FINRA issued an acceptance, waiver and consent (“AWC”) against a firm and its global anti-money laundering (“AML”) Compliance Officer (“CO”) for failures in AML compliance regarding brokerage and custodial...more

The Cost Of Compliance

The title for this posting is a little ambiguous. What is the “cost” of compliance? Is it the cost of implementing an “effective” compliance program? Or is the “cost” to the company of an “ineffective” compliance program. ...more

3 Basic Steps to Improving the Effectiveness of Anti-Bribery Training

To say anti-bribery training is important is one huge understatement. It continues to be one of the key elements in any effective or any best practices compliance program. The US Sentencing Guidelines contains clear language:...more

Miners Triumph And Opinion Release 14-01

On this date in 1966, the Texas Western University (now UTEP) Miners won the NCAA Basketball Championship, beating the University of Kentucky Wildcats. Now the first round has not even started by March 19, but it is not the...more

When To Bring In Investigative Counsel And Why

When should you bring in a true outsider to handle an internal investigation? What about specialized investigative counsel? Jim McGrath, who often writes about the need for specialized investigative counsel, has also pointed...more

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