Chief Compliance Officers

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FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

New Laws Affecting California Employers: Anti-Harassment Protections for Unpaid Interns, Anti-Bullying Training for Managers, and...

California employers need to be aware of three important employment laws that were recently enacted. Effective immediately, California’s existing discrimination and harassment laws have been extended to unpaid interns....more

How To Identify The 14 Red Flags Of Ethical Misconduct & Mitigate Them With Your Compliance Training Program: Part 1

This week I had the pleasure to attend SCCE’s 14th Annual Compliance & Ethics Institute in Chicago. The first session I attended was led by Carolyn S. Egbert, Owner and Founder of Creative Solutions for Executives. Her...more

The Research Is In: Busy People Are Less Compliant

Demanding work environments are common today. But new research has identified a previously hidden cost to pressure-filled organizations, says Gretchen Gavett of the Harvard Business Review: “neglecting those secondary tasks...more

Bribery at the “Sharp End.” Lessons from the field.

To many, an understanding of corruption, bribery and compliance comes from the field of regulators, auditors, investigators and attorneys. Each one of these practices brings an important perspective and set of compliance...more

Weeding Out Bad Actors: The Rule 506 Bad Actor Provisions and Capital Markets Practice – One Year Later

As we approach the anniversary of the effectiveness of the Rule 506 bad actor provisions (if you don’t happen to have it marked on your calendar, the new rules went into effect on September 23, 2013), it is a good time to...more

Here's why Whistleblowing should be on your priority list

The G20 Say... "Priority number one: whistleblowing" - Whistleblower protection laws have been in place for over two decades in some countries. But it's only recently that affective laws and procedures have begun to be...more

Use of Influence in the Compliance Function

One of the challenges for any Chief Compliance Officer (CCO) is how to influence the conduct and actions in a corporate environment, particularly as compliance is viewed as non-revenue generating and usually does not exist...more

Bad News Barnes and China’s Overseas Efforts to Fight Corruption

I thought about Bad News Barnes whilst reading some recent Financial Times (FT) articles about China’s fight against corruption. They were “China takes its anti-corruption battle to foreign shores” and “China bribe cases pose...more

How To Integrate E-Discovery Into Business Processes In Five Steps

With little notice, compliance officers, in-house counsel, and other legal professionals for organizations in the oil and gas industry may be required to hand over sensitive files in response to compliance, regulatory, or...more

Bruce Levenson Takeaways, Plus 5 History Lessons To Add “Oomph” To Your Business Ethics Training

It’s amazing to me that we’ve made it to 2014 and we’re still hearing widespread reports of racism and race-based harassment and discrimination. In 2013, the EEOC received 8,519 race-based harassment and discrimination...more

Where the Action Is: The SCCE Annual Meeting

If anyone wants proof that the compliance profession is on the rise, if anyone still doubts that the young professional of compliance is rapidly growing, all you have to do is attend an annual meeting of the Society of...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Pt 3

The foreign payments cases held the organization and the individuals involved accountable while improving corporate governance for the benefit of the shareholders in the future. A series of cases followed the initial filings....more

Four steps to manage your whistleblower complaints

How do you manage your whistleblower complaints? Getting employees to speak up when they see signs of wrongdoing is hard. Many employees struggle with initially "taking the plunge" (because that's how it may feel) for...more

The Origins of the FCPA: Lessons for Effective Compliance and Enforcement: Part Two

The illicit or foreign payments cases - The preliminary inquiry was followed by formal SEC investigations early in 1974. The resulting cases would become known as the “illicit or foreign payments” cases. The focus of...more

The NFL’s Handling of Ray Rice Shows Need for Consistent Enforcement of Policies and Compliance Training

To say I’m a football fan is putting it mildly. You will find my family cheering loudly at the TV during Falcons games. (How ‘bout that overtime win over the Saints?!) And while it’s not often I get to blog about football,...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

The Importance of an Effective Compliance Program

On September 9, 2014, Brent Snyder, Deputy Assistant Attorney General of the U.S. Department of Justice Antitrust Division, provided prepared remarks on the subject of “Compliance is a Culture, Not Just a Policy,” before the...more

Use of HR in Your FCPA Compliance Program [Video]

In this episode of the FCPA Compliance and Ethics Report, I discuss how HR can help to facilitate your compliance program. ...more

“Culture of Compliance” Urged by FinCEN

Following months of rumors that the Financial Crimes Enforcement Network (FinCEN) is preparing to impose personal liability on officers, directors and employees for shortcomings in their financial institutions’ Bank Secrecy...more

FCPA Compliance and Ethics Report-Episode 87, what are internal controls, Part II [Video]

In this Part II of What Are Internal Controls? I continue my discussion with noted expert Henry Mixon on the basics of internal controls in a best practices FCPA compliance program....more

King Arthur’s Roundtable – The CCO as Chief Collaboration Officer

Many commentators such as Donna Boehme and Mike Volkov often talk about what is required for the position of Chief Compliance Officer (CCO), both in terms of corporate support and skills as a leader of a company’s compliance...more

The Human Factor: Joint Venture Partner Compliance (Part III of III)

It is time for another in my series of profound grasps of the obvious – compliance comes down to people. A company violates its code or the law because of human actions or inaction....more

What Are Internal Controls, Part I [Video]

In this episode of the FCPA Compliance and Ethics Report, I begin a series on internal controls, with noted practitioner Henry Mixon. This is the first part of a two part episode on the basics of what are internal controls. ...more

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