News & Analysis as of

Chief Compliance Officers

Leadership Lessons from James Madison

by Thomas Fox on

I continue my leadership series based upon the lives of US Presidents by looking at leadership lessons from the fourth President, James Madison. Madison lived a life full enough for several people. He served as both a member...more

Retaining a “Risky” Third-Party

by Michael Volkov on

Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or...more

Wake Up and Mind Your Culture — Practical Approaches to Managing a Company’s Culture

by Michael Volkov on

Ethical culture is the flavor of the year these days. We are seeing more postings and articles about the importance of ethical culture, and even pushing the idea of measuring and monitoring culture....more

Leadership Lessons from Dunkirk

by Thomas Fox on

There are several leadership lessons which I believe can be learned from the British (and German) experiences at Dunkirk, which was a series of battles, campaigns and events that lasted from May 25, 1940 until June 4, 1940....more

Every CCO Needs Authority + Autonomy + Resources

by Michael Volkov on

Chief compliance officers are the rising stars in the corporate governance world. However, CCOs have to avoid complacency. CCOs have a lot more to accomplish — it is almost as if the profession has put its collective foot...more

Get Your Board On Board

by Michael Volkov on

Sometimes my references to Seinfeld episodes or Curb Your Enthusiasm vignettes do not work or can charitably be characterized as a little off. Nonetheless, I press on....more

New FASB Revenue Recognition Standard-Revenue from Contracts with Customer

by Thomas Fox on

We are now less than six months away from a new Revenue Recognition standard which may significantly impact the compliance profession, compliance programs and compliance practitioners going forward....more

Maximizing Compliance Opportunities: Your Vendor Onboarding Process and Vendor Master File

by Michael Volkov on

Compliance practitioners are opportunists. They have to look for openings in the corporate resource world to build partnerships with related functions. To put it another way, they are purveyors of compliance thinking – they...more

Good-Bye to the Wichita Lineman – Know Your Values and Stay True to Them

by Thomas Fox on

Glen Campbell died yesterday. He was truly an American original. He grew up dirt poor, as a sharecropper’s son, near Delight (pronounced DEE-light), Arkansas and went onto to achieve worldwide fame. While many will remember...more

Kon-Tiki and Bold Leadership in the Corporate Setting

by Thomas Fox on

According to This Day in History, on this day 70 years ago, the balsa raft Kon-Tiki, captained by Norwegian anthropologist Thor Heyerdahl, completed a “4,300-mile, 101-day journey from Peru to Raroia in the Tuamotu...more

What Happens When Employees Stop Speaking Up?

by Michael Volkov on

One of several difficult compliance questions facing companies revolves around reporting of employee concerns. If the number of complaints coming in on a company hotline goes down over time, is corporate misconduct going down...more

With a New FBI Chief, Compliance Cops Remain on the Beat

by NAVEX Global on

Leaders of organizations across the country might be tempted to view the appointment of Christopher Wray, confirmed as the new head of the FBI on Tuesday, as a sign the new administration plans to ease up on regulating...more

Workplace Ethics & Culture: What the Uber Board Report Means for Compliance Officers

by Thomas Fox on

A compliance perspective on one of the most unique corporate documents you will ever see....more

Hospice Quality Reporting Program Notices of Noncompliance and Reconsideration Requests

by Poyner Spruill LLP on

The Centers for Medicare and Medicaid Services (CMS) has issued notification letters to hospice providers that are not in compliance with the Hospice Quality Reporting Program requirements. According to CMS, all noncompliance...more

Building an Effective Compliance Program

We both recently returned from presenting to groups of health care providers on creating and implementing effective compliance programs. Although compliance plans and compliance programs are not new to the health care realm,...more

Chief Compliance Officers Beware

by Carlton Fields on

In recent years, financial regulators have increasingly taken enforcement action against chief compliance officers (CCOs) and others in compliance oversight roles, rather than just against their employers....more

UPDATE: New UK Offences of Failure to Prevent Facilitation of Tax Evasion – looming deadline

by Ropes & Gray LLP on

In May 2016, we published an Alert about UK proposals to introduce new strict liability corporate criminal offences aimed at preventing the facilitation of tax evasion. Andy Howard, Tax partner in the Ropes & Gray London...more

FCPA Risks and Acquisition Integration Challenges

by Michael Volkov on

Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more

Compliance and Plan C: Operationalization During Economic Uncertainties

by Thomas Fox on

The current economic climate continues to be in flux, with many companies falling back to Plan C, which is hunker down and ride things out until the next Presidential election and hope for some clarity in 2020. This obviously...more

Clarence Darrow, the Scopes Monkey Trial and Leadership

by Thomas Fox on

Today we honor one of the ‘Trials of the Century’ from the 20th century, as on this day in 1925, the Scopes Monkey Trial ended with defense attorney Clarence Darrow giving one of his greatest closing arguments, asking for his...more

Evolutions in Whistleblowing: What Federal Contractors Need to Know

by PilieroMazza PLLC on

Last year produced major changes in the whistleblowing landscape: whistleblower protections for federal contractor employees who disclose waste, fraud, and abuse were made permanent under the National Defense Authorization...more

CCO’s and Delusions About a Company’s Ethical Culture

by Michael Volkov on

It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry....more

Insider Trading: Five Reminders From the SEC Division of Enforcement

A recent litigation release from the SEC Division of Enforcement, though seemingly unremarkable, highlights five basic principles that sometimes slip off a company’s insider trading compliance radar. ...more

Anti-Corruption Digest - July 2017

by Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

Astros Lead MLB – What is Your Risk Management Process?

by Thomas Fox on

Today’s lesson from the world of sports informs our discussion of compliance and the risk management process; consisting of forecasting, risk assessment and risk management. By starting with forecasting, a compliance function...more

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