Chief Compliance Officers Compliance

News & Analysis as of

Benchmarking Your FCPA Compliance Program

After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more

New York Department of Financial Services Issues New AML and Sanctions Regulations

The New York DFS finalized its new AML and Sanctions screening regulations. Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the...more

SEC Issues Guidance on Business Continuity Planning for Registered Investment Companies

On June 27, the staff of the Securities and Exchange Commission’s (Commission or SEC) Division of Investment Management (IM) issued a Guidance Update on business continuity planning for registered investment companies...more

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more

Innovation in Compliance Week, Part II-Superforecasting

I continue my Innovation in Compliance series today by discussing “superforecasting” and its use by a compliance function. Imagine that as a Chief Compliance Officer (CCO), you could create a team which might well...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Harry Potter, Whistleblowers and Compliance

One of the things I have enjoyed for years is listening to some of America’s top professors and academics that teach in their subject area of expertise through lectures from the Teaching Company. I just completed the 24...more

The King’s Guitarist and Leadership

We recently lost some legendary musicians. Last week two of the biggest from very different genres left us. They were Scotty Moore and Dr. Ralph Stanley. Today I want to pay tribute to Scotty Moore, recognized by Rolling...more

When Lawyers Get in the Way of Compliance

I hate to pick on lawyers. I have been practicing law for nearly 35 years. I have worked with and met a lot of lawyers, some great, some good and some not so good. Lawyers can sometimes be their own worst enemies. When...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

Shearman & Sterling’s bi-annual Trends & Patterns 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 practices in FCPA...more

Convergence of Audit and Compliance Functions

Returning to the serious subject of compliance, there are some who argue that compliance is a lot simpler than professionals and commentators tend to describe. I am an advocate for simplicity as a way to ensure adoption of...more

Compliance Meaningfulness: Hard to Achieve, Easy to Destroy

In an article titled, What Makes Work Meaningful- Or Meaningless by Catherine Bailey and Adrian Madden (MIT Sloan Management Review, Summer 2016), the authors focus upon what makes our work meaningful, with research...more

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Good-Bye to Mr. Hockey and Curiosity in a CCO

Gordon ‘Gordie’ Howe died last week. To most of North America he was simply known as “Mr. Hockey”. In his first hockey career, he played in a by-gone era of what we now call the ‘Original 6’ where two Canadian teams and four...more

A Rush to Compliance: Patience is a Virtue

Compliance officers are, by definition, goal driven. They are high achievers and expect to succeed. So what. You may say – we all know that. Compliance officers are not the most patient group of people. They want to see...more

[Webinar] How do I Keep All My Employees—From Millennials to Boomers—Engaged with Compliance Training? - June 24th, 10:30am...

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about Ethics & Compliance Training....more

[Webinar] Why Do I Need Multiple Intake Methods for Incidents? - June 17th, 10:30am PT/1:30pm ET

Join NAVEX Global and a group of your peers for a short session where we’ll answer your questions and share solutions about incident management reporting....more

FCPA Compliance and Ethics Report-Episode 258-using data, data analytics and data analysis in your compliance programs [Video]

In this episode, I consider how a CCO can use data in a best practices compliance program. ...more

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

Tribute to Ali – The Greatest

The Greatest died this past Friday. There is only one man in my lifetime who earned that sobriquet and it was Muhammad Ali. Ali was the greatest sportsman in my lifetime and in 1999, he was named by the editors of Sports...more

A COSO Look at Control Objectives

Brian Christensen, in an article in Corporate Compliance Insights (CCI) entitled “The Updated COSO Framework: Time for a Fresh Look at Internal Control”, said that the updated 2013 COSO Framework retained the core definition...more

Want to Work in Compliance – Learn How to Read a Balance Sheet

One of the most interesting tag lines I heard at Compliance Week 2016 was the following, if you want to work in my compliance department; you need to learn how to read a balance sheet. I thought that single line encapsulated...more

Ghostbusters, Compensation and Compliance

This summer heralds a remake of one of the most iconic movies of recent vintage, I refer, of course, to Ghostbusters. After all, ‘who ya gonna call? Unlike the original movie and its sequel which starred Bill Murray, Dan...more

Do Former Prosecutors Make Good CCOs?

A number of companies have adopted the requirement that a new Chief Compliance Office come from the ranks of former federal prosecutors. I am not sure exactly why companies have adopted this requirement. Perhaps company...more

The Non-Pairing of Two Great Sports Announcers: Lessons for the CCO

I grew up listening to the Houston Astros on the radio. It was not because my family was totally retro. We were not that cool at all, it was simply at the time I grew up, in a time, the 1960s and a place, Bryan, Texas, where...more

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