Chief Compliance Officers

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Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a...more

US Commodity Futures Trading Commission Approves Rule Amending Chief Compliance Officer Annual Report Timing for Certain...

The US Commodity Futures Trading Commission announced its unanimous approval of a final rule amending CFTC regulation 3.3 to provide for a 90-day window after the end of an institution’s fiscal year for the filing of chief...more

On Leadership – A Simple Message and Asking the Right Questions

Sometimes, as a leader it is important to say something numerous times, to repeat your message so that it will come through loud and clear. For any Chief Executive Officer (CEO) it is incumbent to continually reinforce your...more

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more

The Myths Surrounding Ethics and Compliance Programs

Chief compliance officers have a difficult job. That is a real profound grasp of the obvious. CCOs face an unending onslaught of tasks, risks and juggling of concerns and activities. On many respects, a CCO’s job is never...more

Do You Know and Understand Your Compliance Policies?

My question appears to be fairly obvious, right? This is not a question or a quiz of every chief compliance officer. Rather, this is a question for everyone but the CCO and compliance and legal staff. Think about it....more

Infusing Your Compliance Program with Business Ethics

It is important to remember that companies are required to implement an ethics and compliance program. Ethics should not ever be a segregated issue carved off from a compliance program. They walk hand-in-hand, and reinforce...more

When Managing Whistleblower and Retaliation Risk, Tools are Important – Processes and People are Critical

One collection of terms I hear a lot is “tools, processes and people.” All three need to be successfully deployed to make a compliance program run properly while also creating an organizational culture that supports...more

When Tone at the Top Is Missing

We all tend to gloss over a critical requirement for an effective ethics and compliance program – tone-at-the-top. I hate to be dogmatic about the issue but, as Mel Brooks said in the Curb Your Enthusiasm (Season 4, Episode...more

CFTC Approves Final Rule for Filing Chief Compliance Officer Annual Reports

The CFTC approved a final rule amending a CFTC regulation addressing the timing for filing chief compliance officer annual reports for certain registrants. The final rule amends CFTC regulation 3.3 to provide futures...more

Corporate and Financial Weekly Digest - Volume XI, Issue 44

SEC Issues New C&DI Relating to Submission of Annual Reports to SEC - On November 2, the Division of Corporation Finance (Division) of the Securities and Exchange Commission issued a new Compliance and Disclosure...more

Corporate and Financial Weekly Digest - Volume XI, Issue 44

SEC Issues New C&DI Relating to Submission of Annual Reports to SEC - On November 2, the Division of Corporation Finance (Division) of the Securities and Exchange Commission issued a new Compliance and Disclosure...more

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Making Sure Business Ethics Has a Seat at the Table

Everyone likes to cite and talk about the list of horrible scandals. Whether it is Enron, WorldCom, Siemens, GM, VW, Wells Fargo, we pick through the details, cite failures and use it as a springboard to a discussion of...more

An Effective Manual Compliance Program is an Oxymoron

No matter how proficient a compliance professional you may be, the deck is stacked against you if you are not automating your ethics and compliance program in the same ways other functional groups are automating their...more

The Unsinkable Molly Brown – Compliance, Stakeholder Engagement and CSR

Tammy Grimes died earlier this week. For those of you not familiar with that name, you may well know the name of the Broadway musical which catapulted her to fame, The Unsinkable Molly Brown. Grimes garnered a Toni in 1960...more

Rethinking Stakeholder Engagement for the New Millennium – Part II

This week, I began a two-part series based upon recent Research Report (Report) issued by BSR entitled “The Future of Stakeholder Engagement”, authored by Sara Enright and Alison Taylor, with additional guidance and insights...more

When Lawyers Cross the Line – Breaking Bad Under the Law

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more

Embraer FCPA Enforcement Action – Part II

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Will Your Ethics Hold Up Under Pressure?

Waiting to see if your organization’s ethical fabric is as bullet proof as you hope isn’t a great strategy - No executive wants to wake up and find themselves on the cover of the Wall Street Journal, exposed in some...more

When Business Supersedes Compliance – A Recipe for Disaster

When looking through the wreckage of a major corporate compliance disaster, it is relatively easy to spot the important events when business needs (or money) are consciously elevated over compliance concerns or even...more

Bridging the Week - October 2016 #3

Registration Based on Quantitative Test Likely to Be Part of Supplemental Regulation AT, Suggests CFTC Chairman - Timothy Massad, Chairman of the Commodity Futures Trading Commission, indicated last week that he...more

Defending parallel proceedings: key considerations and best practices

Parallel proceedings refer to two or more concurrent investigations or litigations arising out of a common set of facts. These proceedings can involve any combination of criminal, civil, or administrative authorities, as well...more

Tangled Up in Blue and Rethinking the Role of the Compliance Professional

Today, I conclude my tribute to Bob Dylan-Nobel Laureate, by discussing my personal favorite Bob Dylan song, Tangled up in Blue. The time shifts and jumps in the song have always resonated with me. Indeed, it is one of the...more

Four Practical Tips For K-12 Title IX Compliance

Administrators at K-12 school districts around the country have enormous responsibilities, with Title IX compliance high up on their list. While all administrators are concerned with doing the right thing by their students,...more

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