Chief Compliance Officers

News & Analysis as of

Why It's Wise to Pay Attention to Your FCPA Compliance

Companies in the automotive industry would be wise to pay attention to Foreign Corrupt Practices Act (the “FCPA”) compliance. What has in the past been a risk management issue principally for massive multi-national...more

Compliance Programs under the Brazilian Clean Companies Act

According to the World Bank, Brazil is the world’s seventh wealthiest economy, with a Gross Domestic Product (GDP) of US$ 2.253 trillion in 2012. On the other hand, Brazil is ranked 69th out of 175 countries in Transparency...more

Corporate Branding and Ethics and Compliance Charters and Policies

There is a lot written on the value of symbols in political and public relations campaigns. My favorite President, Franklin Roosevelt, was a master at using symbols to communicate powerful ideas to the public....more

Compliance Program Effectiveness Requires Accountability

A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable....more

Appreciative Inquiry and Servant-Leadership

So, you have done your cultural assessment, you have identified gaps that need to be addressed in terms of change, and you’re ready to take action. The first tool we’ll explore with you is known as Appreciative Inquiry (AI)....more

Trust in the Balance

This tough Cookie is grateful to have been asked to submit some articles for Tom Fox while he visits with his daughter during Spring Break. When I pondered what would be an appropriate topic for the week, immediately...more

The Gathering Momentum of Anti-Bribery Enforcement in Australia

Today’s interview is with Julian Fenwick and Jane Ellis, both Anti-Bribery Compliance Professionals in Australia. Given the recent reporting concerning anti-bribery, corruption, and compliance issues in Australia, I thought...more

The Importance of Organizational Justice

A company is its own world. A culture of ethics and compliance cannot exist without organizational justice. If company managers and employees perceive that the internal justice system does not work, the company will be...more

Compliance Responses to Economic Downturns: A Focus On The Energy Sector – Part Two

II. Doing Less with Less - The current economic downturn in the energy space seems to follow a pattern, with businesses’ exhibiting predictable Pavlovian responses. When oil prices drop precipitously, companies who are...more

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part V – Final Thoughts

I conclude my week of exploration of Agatha Christie’s Miss Marple short stories and the Securities and Exchange Commission’s (SEC) enforcement of the Foreign Corrupt Practices Act (FCPA) by reviewing some of the new things...more

Ingots of Gold & SEC FCPA Enforcement – Communication – Part IV

Today I want to use the Christie’s story Ingots of Gold as an introduction to some of the regular communications that the Securities and Exchange Commission (SEC) representatives frequently provide in public forums, regarding...more

Ethics and Compliance, Not Compliance and Ethics

I have several pet peeves in the ethics and compliance space (who knows, maybe in the personal space as well but we are all reluctant to acknowledge those except to our loved ones)....more

Does Compliance Need More “Darkside”?

Since my release from the Federal Prison Camp in December 2013, I have been observing many different perspectives in the compliance discourse that have broadened my own understanding of “compliance”. From the fields of law,...more

Compliance Reponses to Economic Downturns: A Focus On The Energy Sector

I. The Problem - As I write, oil is hovering around $50 per barrel. The price will inevitably rebound, but all compliance officers need to be prepared for responding to economic downturns in their respective industries...more

FCA Fines Bank, Compliance Officer And Internal Auditor For Providing Misleading Information To The FCA

A decision report and comment on the FCA's decision in March 2015 to fine and publicly censure a bank, its compliance officer and its internal auditor for providing misleading information to the FCA. Originally...more

New York's Lawsky Proposes SOX-Style Personal Accountability for Anti-Money Laundering, Foreign Asset Compliance

It is, by now, common practice for financial institutions (and other businesses as well) to adopt and maintain comprehensive and costly Anti-Money Laundering (AML) and Office of Foreign Assets Control (OFAC) compliance...more

SDNY US Attorney Preaches to Choir; Lauds Financial-Industry Gatekeepers

Addressing the annual meeting of the Compliance & Legal Division of the Securities Industry and Financial Markets Association, Manhattan U.S. Attorney Preet Bharara stressed the importance of industry compliance and legal...more

Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III)

Sometimes a picture is very clear but legal words and concepts are proffered in an attempt to disguise and even deceive. As set forth in the factual statements outlined by the government, and agreed to by Commerzbank, it is...more

Webinar - Benchmarking Your Hotline in 2015: How Does Your Data Measure Up?

Ethics officers agree—one of the most effective ways to measure your compliance program is by analyzing data from internal reporting systems. But how can you know what is good or bad without context? We’ve compiled...more

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part I

I am a huge Agatha Christie fan. I have read most of the Poriot novels and many of the Jane Marple novels as well. However, I was not aware of Christie’s work in the short story format until I recently read a volume entitled...more

Who's in the House? Recent Moves by General Counsel, Legal Officers, and Corporate Leaders

A look at recent moves and promotions for general counsel, in-house lawyers, and other corporate leaders in the field for the week of March 16, 2015....more

Letter From America: Internal investigations – a stark reminder of the dangers of failing to implement strict protocols from the...

A recent ruling in long-running civil litigation against the Bank of China (“BOC”) in the United States District Court for the Southern District of New York provides a stark reminder of the dangers of failing to develop and...more

OCC Comptroller Delivers Remarks Regarding BSA/AML Compliance

On March 2, OCC Comptroller Curry delivered remarks before the Institute of International Bankers regarding BSA/AML compliance obligations for financial institutions. During his remarks, Comptroller Curry emphasized that a...more

Responsibility, Accountability and the FCPA Institute in Houston

What is accountability in your compliance program? How does it relate to responsibility for a company to prevent, detect and remediate any issues that might arise under a Foreign Corrupt Practices (FCPA) compliance program?...more

Technology is Transforming Third Party Risk Management: Predicting the Future

I usually avoid predicting the future because I am often wrong. But in this case I’m going to make an exception. Here is my 100 percent, sure-to-be true prediction: technology is going to change how compliance professionals...more

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