Chief Compliance Officers

News & Analysis as of

Astros in the Playoffs, Will Hell Freeze Over?

When recently I contacted the Underworld about the potential listing of this vast property, I was stunned when Satan himself answered the phone. While I was tempted to ask what happened to all his hired help down there,...more

OFCCP Publishes Final Rule to Promote Pay Transparency

On September 10, 2015, the Office of Federal Contract Compliance Programs (OFCCP) published its final rule on pay transparency. The purpose of the rule is to prohibit “pay secrecy policies” to make it “possible for workers...more

The Psychology of Cheating and FCPA Compliance

In the movie Margin Call, Jeremy Irons intones that there are three ways to win in business: (1) be the smartest; (2) be the fastest; and (3) cheat. I am currently out at the SCCE 2015 Compliance and Ethics Institute and as...more

Bristol-Myers Squibb FCPA Enforcement Action

Yesterday, the Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action against Bristol-Myers Squibb Company (BMS) for the actions of the company’s joint venture (JV) in...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

SEC Commissioners Making a “Noisy Exit”

Securities and Exchange Commission members Daniel M. Gallagher and Luis A. Aguilar will soon leave the SEC, but neither is keeping quiet about the SEC’s treatment of chief compliance officers (CCOs). Gallagher recently...more

5 Success Factors in Cutting-Edge Compliance: Compliance Becomes King When These Elements Are Integrated Into Day-to-Day...

Technology is doing more than bringing compliance fully into the digital age. It’s also initiating a revolution that is putting compliance and ethics at the forefront of how business is run, creating far greater operational...more

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement Cybersecurity Is At the Top of SEC Examination Concerns In a recent SEC “risk alert” for registered broker-dealers and investment advisers, the SEC’s Office of Compliance Inspections and Examinations (OCIE)...more

Department of Justice Issues Guidance on Corporate Investigations and Executive Accountability

On September 9, 2015, Sally Quillar Yates, Deputy Attorney General of the Department of Justice (DOJ) issued a memo entitled “Individual Accountability for Corporate Wrongdoing” to address the issue of incentivizing...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

The Compliance Dangers of Cheerleaders and Nay-Sayers

Compliance always boils down to people and interpersonal relationships. No man is an island, and no one can go it alone in compliance. One essential requirement for effective compliance is the ability to engage colleagues and...more

DOJ Sets Its Sights on Directors and Officers

Whether publicly traded or privately held, corporate boards have been put on notice – the Department of Justice (Justice or DOJ) is after you! On September 9th, DOJ issued a memo entitled: Individual Accountability for...more

How Can the Automotive Industry Strengthen Its Regulatory Compliance Process and Reduce Its Compliance Risks?

Many Americans listened last week to the admissions by the now former President of Volkswagen that the company had been “dishonest” and had cheated on the U.S. emissions tests. How was this happening at the world’s #1...more

Five Ways to Ensure Board Support for Compliance

A Chief Compliance Officer has a number of important relationships to maintain in an organization. Aside from the support of senior level executives, the CCO has to build an effective working relationship with the board and...more

VW Emissions Testing Scandal – View from the Board

The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “Problems at VW Start at the Boardroom”, James B....more

DOJ Focuses on Individual Accountability: New Guidance for Corporate Investigations Places Pressure on Companies and Boards to Put...

On September 9, 2015, the Department of Justice (“DOJ”) issued new guidance on individual accountability for corporate wrongdoing. In the memorandum and an accompanying speech by the Deputy Attorney General Sally Q. Yates,...more

Colombian Companies Face New Compliance Challenges as Nation Ascends to World Economic Stage

When OFAC added Colombian sports franchise Envigado Fútbol Club to its sanctions list in June 2014, the news conjured up echoes of past dark days of “narco fútbol,” when the tentacles of organized crime touched the country’s...more

What's So Great About an Information Security Policy?

Lawyers and compliance professionals constantly tout the importance of internal information security policies, particularly in light of data privacy problems that are reported almost daily in the media. Admittedly, drafting...more

Compliance Fatigue — A Dangerous Concept

I have a lot of pet peeves, especially when it comes to lawyers and compliance professionals. Do not worry this is a not a column about all of my pet peeves; I would never bore you with all those issues....more

Corporate political law compliance for the 2016 election cycle: Candidate appearances on corporate property

With summer finally at an end and the 2016 election season already in high gear, the time is ripe for corporations of all sizes to begin reviewing their existing political law compliance frameworks and refreshing their...more

Channeling Yogi Berra to Find Smart Risk in Compliance

Yogi Berra died yesterday. In addition to being one of the greatest catchers in baseball, he was a 3-time Most Valuable Player (MVP), a 15-time All Star, a Hall of Famer and member of the All-Century Team, a player on 10...more

Corporate Executives in the Cross-Hairs: U.S Department of Justice Amps Up Quest for Individual Accountability for Corporate...

This month, the United States Department of Justice issued an unambiguous directive to its army of white-collar prosecutors – hold individuals accountable. By publishing its “new” internal policies to the New York Times, it...more

Cleaning Up a Compliance Program Mess

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5...more

Monitors Third Annual Report

This is the third annual report of the independent athletics integrity monitor (“Monitor”) pursuant to article IV of the Athletics Integrity Agreement (“AIA”) among the National Collegiate Athletic Association (“NCAA”), The...more

The Keys to a Successful International Compliance Hotline: And the Hidden Potential It Hides

If you are creating or expanding your call center internationally, or already have one, you have the potential to organize the data coming in ways that can change a company’s direction and impact its bottom line....more

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