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Chief Compliance Officers

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

This Week in FCPA-Episode 54, the Rubber Match Edition [Video]

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Day 20 - Compliance Leadership from the Bottom [Video]

by Thomas Fox on

The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the following question - “How is...more

The Compliance Profession Needs to Adopt Professional Standards

by Michael Volkov on

Those who regularly read my blog have heard me often cite the need for the compliance profession to adopt professional standards. With the rise of the profession, and the expectations placed on the shoulders of compliance...more

Operationalizing Compliance: Part IV – Internal Audit

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

Operationalizing Compliance: Part III – Human Resources

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

by Thomas Fox on

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Operationalizing Compliance: Part II – Breaking Through Obstacles

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture [Video]

by Thomas Fox on

The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical culture is an important step...more

CFTC Proposes to Amend Chief Compliance Officer Duties and Annual Report Requirements

by Morrison & Foerster LLP on

On May 3, 2017, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to its rules regarding the duties of Chief Compliance Officers (“CCOs”) for swap dealers...more

Operationalizing Compliance: Part I – It All Starts with Pizza

by Thomas Fox on

With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper...more

The Astros, Regression to the Mean and Compliance

by Thomas Fox on

Being a Houston baseball fan has been largely pain, misery and suffering. While we have not gone 80+ years or even a century without winning a World Series it is not for lack of ineptitude. It is because the Houston Major...more

Compliance Program Oversight - The Board’s Overlooked Role

It’s long been axiomatic that an effective compliance program cannot exist without a strong ethics and compliance culture, which in turn requires the proper “tone from the top.” Yet, when most companies think “top,” they...more

The Renovated Globe Theater and Operationalized Compliance

by Thomas Fox on

There is much that a Chief Compliance Officer (CCO) or compliance practitioner can learn from Shakespeare. I have often used his plays as introductions to blog posts or as examples to inform a compliance program. Today, I...more

Effective Compliance and the Importance of Accounts Payable Function

by Michael Volkov on

As the compliance function has matured, Chief Compliance Officers have built important relationships with related functions that are critical to the compliance function. Over the last few years, we have seen the Justice...more

From Dr. No to an Agile Compliance Program

by Thomas Fox on

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

The State of Mind of a White Collar Criminal

by Michael Volkov on

As a chief compliance officer, it is important to consider the mindset of a criminal. Not to complete tasks and accomplish your objectives. Instead, it is important to understand the criminal mind, what makes them tick and...more

Setting Your Compliance Program by the North Star

by Thomas Fox on

Today I celebrate a potpourri of history to lead into some leadership lesson for a Chief Compliance Officer (CCO) or aspiring CCO. According to This Day In History, today marks the second formation of the Committees of...more

MoneyGram CCO Pays Civil Penalty

by Michael Volkov on

Like any other profession, the compliance profession is not immune to bad apples. Lawyers know the law but have been criminally prosecuted for breaking the law. The same goes for compliance professionals....more

Orrick's Financial Industry Week In Review

Financial Industry Developments - CFTC Proposes to Amend Rules Governing Chief Compliance Officer Duties and Annual Reports for Certain Registrants - On May 3, 2017, the U.S. Commodity Futures Trading Commission...more

Don’t Outsmart Yourself: AI and Compliance

by NAVEX Global on

I’m a big fan of artificial intelligence. The older I get, the more I appreciate that real intelligence needs all the help it can get. Corporate ethics and compliance officers, however, need to pause before betting big on AI...more

The Compliance Profession and the Demand for “Results”

by Michael Volkov on

Compliance professionals are riding high. They are the darlings of the corporate governance world, commanding higher salaries, C-Suite positions with access to senior leadership and the board, and an empowered position within...more

The Trump Administration: The Business Impact

by Thomas Fox on

If we do not speak up, there may not be an opportunity later. ...more

Four Essential Leadership Behaviors

by Thomas Fox on

The role of any leader should be engagement, engagement and then more engagement. By understanding the needs of your key stakeholders and incorporating that into your solution or initiative you will have your team on board...more

The Danger of Corporate Scandals – When CEOs and Senior Executives Circle the Wagons to Impugn a CCO

by Michael Volkov on

We all know the scenario. A corporate scandal breaks, heads will roll and criminal investigators have invaded a company to investigate and prosecute the CEO, senior executives and others. It is a toxic environment when this...more

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