News & Analysis as of

Chief Compliance Officers

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

Trump and Compliance: The First 100 Days [eBook]

by Thomas Fox on

Since November 9, 2016 the Apocalypse has not descended (at least as of the writing of this foreword). Since that time many of the leading compliance commentators have considered what the first 100 days of the Trump...more

FCPA Digest - July 2017 - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

OSHA Inspections are on the Rise: Will You Be Ready?

by Foley & Lardner LLP on

As employers, manufacturers are aware of their responsibility for knowing the safety standards applicable to their businesses. But many do not understand their rights and obligations during the inspection process. In recent...more

Using Your Employees to Innovate and Transmit the Message of Compliance

by Thomas Fox on

Yesterday I wrote about the use of internal employee crowdsourcing as an innovation tool for a Chief Compliance Officer (CCO) to enhance a best practices compliance program. Multiple readers noted the topic with approval and...more

The CCO as a Futurist

by Thomas Fox on

Every Chief Compliance Officer (CCO) and compliance practitioner who thinks about their compliance program one, three or five years down the road is a budding futurist. The Compliance Week 2017 Annual Conference opened this...more

The Importance of Compliance Program Audits

by Michael Volkov on

Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’...more

Effective FCPA Compliance Programs: Building a Compliance Defense

by Dorsey & Whitney LLP on

The classic 1957 American mystery film “Three Faces of Eve,” about a woman with multiple personalities, may well describe the approach taken by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

CCO Leadership: Lessons from Kaiser Permanente

by Thomas Fox on

One thing every Chief Compliance Officer (CCO) will face is multiple stakeholders. The more compliance is operationalized the more sensitized this issue will become. Yet the centralized control that many business leaders have...more

Uber’s Troubles: A Compliance Wake-Up Call No Matter How Regulated You Are

I can’t help myself; when I read some of the troubling reports about Uber’s workplace culture, which has contributed to executive ousters and the need to hire one of the highest-profile lawyers in the country, I think, “If...more

Incorporating Employee Storytelling into Your Compliance Marketing

by Thomas Fox on

As you might suppose I read quite a bit. One of the pleasures I receive each month is when the copy of the MIT Sloan Management Review arrives. I also find the articles highly topical and present ways to consider new...more

CCOs and Resources: Put Your Money Where Your Mouth Is!

by Michael Volkov on

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more

The PCAOB, Audits, and Compliance - Considerations for the Chief Compliance Officer

by Thomas Fox on

I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might...more

Are Risk Assessments Just a Report on the Obvious?

by Michael Volkov on

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more

5 Telltale Signs of a Weak Corporate Culture

by Michael Volkov on

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

Updated U.S. Civil Penalties Raise the Cost of Noncompliance

In 2016, we let you know about the redundantly titled “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” which required that heads of government agencies adjust civil penalties yearly to account for...more

SEC Charges Chief Compliance Officer with AML Violations

The SEC announced that John David Telfer, the former chief compliance officer and anti-money laundering (AML) officer of a registered broker-dealer, agreed to a securities industry bar to settle charges in a pending...more

Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress

by Michael Volkov on

Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more

The Uber Board Report – Part I

by Thomas Fox on

On Tuesday, the law firm of Covington & Burling LLP (Covington), released its long-awaited report (Report) to the Special Committee of the Board of Directors of Uber Technologies, Inc. (Uber). It is truly one of the most...more

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