News & Analysis as of

Chief Compliance Officers Compliance

Attorney General Sessions reemphasizes DOJ commitment to FCPA enforcement, individual accountability: 4 takeaways for business

by DLA Piper on

As the Trump Administration wraps up its first 100 days, practitioners have a bit more clarity regarding how the new Administration will assess corporate compliance programs, cooperation and white collar cases. Over the past...more

Compliance is Not “Rocket Science”

by Michael Volkov on

In the compliance arena, like in many others in life, we value simplicity. I have repeatedly stressed the importance of compliance initiatives that are relatively simple. Too often, lawyers and compliance professionals...more

Data Analysis In a Compliance Best Practices Program

by Thomas Fox on

An in-depth look at the use of data analysis in a best practices compliance program under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other anti-corruption compliance regime....more

Suggested Questions for the Compliance Officer

by Ruder Ware on

In a previous blog post, I promised to release a list of questions a Board of Directors (Board) might ask its compliance officer. This post is intended to fulfill that promise. My intent is to help Board members exercise...more

Writing Tips Inform Your Compliance Program

by Thomas Fox on

Today I consider some tips from the world of fiction composition for your compliance program. These lessons are applicable for both the design, enhancement and implementation of your compliance regime. Moreover, by...more

Exercising Board Oversight of the Compliance Function

by Ruder Ware on

The Board of Directors (Board) of an organization has oversight responsibilities over the compliance program. Board members are often unsure of the nature and scope of their responsibilities over compliance. The roll of many...more

Measuring the Effectiveness of a Compliance Program

by Thomas Fox on

How does one measure effectiveness? In Wichita, Kansas, in 1876, when it came to town a Deputy Sheriff, the final measure was the elected government. On this day in that year, the town’s Commissioners voted not to extend the...more

The Risk Management Process in Compliance

by Thomas Fox on

An exploration of risk forecasting, risk assessment and risk-based monitoring for the compliance profession. ...more

Houston, we’ve had a problem – Compliance Leadership from the Bottom

by Thomas Fox on

While leadership at and from the top has long been considered by both the DOJ and compliance professionals as a key element to move compliance forward, the Evaluation has also crystalized thinking around compliance leadership...more

Farewell to J. Geils – Final Compliance Function Lessons from Wells Fargo

by Thomas Fox on

You may not recognize the full name, John Warren Geils Jr., but you probably do recognize the name J. Geils, as in the J. Geils Band, who died this week. J. Geils was ubiquitous in the 70s and early 80s with, as noted by an...more

Leadership Lessons from Catch-22

by Thomas Fox on

Joseph Heller’s Catch-22 is one of the most famous books and movies from the second half of the 20th century. While it may not seem apparent on first blush, it has several lessons for the Chief Compliance Officer (CCO) to...more

CCOs Say Policies Are Getting Stronger; Adoption of Technology – Not So Much

by NAVEX Global on

KPMG recently published its latest survey of chief compliance officers. The report highlights the increasing value of effective Compliance. It also reveals growing pains of our industry, specifically in maximizing...more

How to garner a NPA and Declination

by Thomas Fox on

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program as there where two public declinations granted by the DOJ for companies...more

Operationalizing Data in a Compliance Program

by Thomas Fox on

The use of data in compliance programs continues to be held up as either a siren’s song or a goal which simply cannot be achieved. Most of the time when compliance practitioners consider how to use big data in a compliance...more

Lawyers and Culture in the Financial Services Industry

by Michael Volkov on

The rise of the compliance profession has had a number of positive impacts on the corporate governance landscape. One of the most important results has been increased focus on corporate culture....more

Defining the Duty of the Board of Directors over Compliance Functions

by Ruder Ware on

I recently posted a blog article about a document released by the Department of Justice entitled “Evaluation of Compliance Programs.” As the title of the document might suggest, the DOJ release covers a variety of issues it...more

Leadership Lessons from the Movies

by Thomas Fox on

Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

by Michael Volkov on

Here is a profound grasp of the obvious – Lawyers can be difficult people. Some like to condemn the profession in its entirety (and carry with them a collection of lawyer jokes). As an attorney, I beg to differ. Many...more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

by Thomas Fox on

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

by Michael Volkov on

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

Doing Business in Cuba Under the FCPA

by Thomas Fox on

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

by Michael Volkov on

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may...more

Managing Your Ethical Culture: Measure, Intervene and Remediate

by Michael Volkov on

In the wake of ever-constant business scandals (e.g. ZTE, VW, Takata, Odebrecht), chief compliance officers have to refresh their approach and strategy. Everyone agrees, or at least I think they should agree, that a company’s...more

Use of Social Media In a Best Practices Compliance Program

by Thomas Fox on

Why should you integrate social media into your compliance program? In a compliance program, a large portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the...more

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