Chief Compliance Officers Compliance

News & Analysis as of

Win-Wins: Looking for Business and Compliance Success

A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more

Brother Can You Spare Some (Compliance) Advice?

Usually I have Houston professional sports teams to hold high as example of true bone headedness around compliance issues. However, as my beloved Houston Astros took the World Series Champions, KC Royals, to the 7th inning of...more

Reading Minds: 5 Ways to Understand a Board of Directors, from the Inside-Out

Compliance managers and leaders offer a common compliant in our roundtables: “no one really listens to us”. It would seem this isn’t imagined. Steven Cohen, Assistant Director of the SEC, said recently, “We are very mindful...more

[Webinar] Corruption and Third Parties: Top Ways to Mitigate Risks - Dec. 1st, 12:00pm EST (3:00pm Brazil)

New laws, increased enforcement and broadened liability increase the urgency for companies working in Brazil to put processes in place to prevent corruption within their own organizations and among their business partners....more

Compliance Counsel Metrics – Part III: Program Evolution and Incentivizing Compliance

Today, we continue our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. These...more

OCIE Issues Risk Alert Relating to Outsourced Chief Compliance Officers

On November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) released the findings of its Outsourced CCO Initiative, which examined nearly 20 investment advisers and investment companies that are...more

Turning the CEO Around: How to Make Sure the CEO Embraces Ethics and Compliance

Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement....more

OCIE Cautions Advisers About Outsourcing Compliance Activities

In a Risk Alert dated November 9, 2015, the SEC’s Office of Compliance Inspections and Examinations (OCIE) said it found that outsourced compliance programs are generally effective, but some of these arrangements leave room...more

Does Training + Code of Ethics = Culture of Ethics?

Complacency in compliance is a cancer on a company’s culture. Woody Allen said it best in Annie Hall: A [compliance program] relationship, I think, is like a shark. You know? It has to constantly move forward or it dies. And...more

DOJ Announces New Compliance Counsel and Outlines Metrics for Evaluating Corporate Compliance Programs Under Scrutiny

In July 2015, the U.S. Department of Justice’s Criminal Division revealed that it was hiring a Compliance Counsel to assist in assessing the quality and effectiveness of companies’ corporate compliance programs under scrutiny...more

Corporate Responsibility for Third-Party Misconduct: The UK Modern Slavery Act of 2015

Companies have long faced serious legal consequences for bribes paid by employees, vendors, suppliers, business partners and other third parties with whom they do business. More recently, that risk has expanded beyond bribery...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Good-Bye to Fred Thompson – What’s Your Compliance Plan?

Fred Thompson died this week. He had a long and distinguished government career including working in the Senate Watergate Committee as a staffer. Thompson was credited for coming with the signature question from the Watergate...more

Celebrate Compliance Week 2015

November 1-7 is Compliance and Ethics Week. I wanted to give you some ideas on how you might use this week’s designation to help bring the message of compliance and ethics to your organization. An oft-raised topic is how to...more

SEC Discusses Criteria for Charging Chief Compliance Officers

In remarks before the 2015 National Society of Compliance Professionals, National Conference, Andrew Ceresney, Director, SEC Division of Enforcement, outlined the type of criteria used to charge Chief Compliance Officers with...more

[Event] 2015 Ethics & Compliance Virtual Conference - Nov. 17th, Virtual

Don't miss the largest ethics & compliance industry event of the year! Brand New Topics & Sessions! * Hear nine engaging sessions—including our Keynote by Governor Thomas J. Ridge—and gain practical takeaways to...more

A Dash Home for the Ages – Using Start-Up Techniques to Further Compliance

Congratulations to the Kansas City Royals for winning the World Series on Sunday night. Watching a franchise that has never won such a championship, I can certainly understand the elation of a team that had not been to a...more

Culture Caution: Should You Accept a New Job as a CCO at a Company?

Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and...more

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Homeland, Brazilian Clean Companies Act Guidance and the Need for Accurate Translations in FCPA Compliance

He used to work in the movie business so you might think the production crew of the Showtime series Homeland would just give him a call. After all he is fast becoming known as ‘the translations guy’ in the Foreign Corrupt...more

[Webinar] Transparency International - USA - CREATe Webinar: From Policies to Practices: Embedding and Verifying Your...

How effective is your anti-corruption program? Companies of every size are vulnerable to legal, reputational and other risks due to corrupt activities among employees and third parties. Gain insights into leading practices...more

Reinvigorating Corporate Board Governance to Embed a Culture of Ethics and Compliance

“It is Time” – Rafiki, The Lion King Corporate scandals continue to rack up – I am not just blowing smoke on this fact. Corporate boards are under greater scrutiny but the hardest place to bring reform is the corporate...more

Promoting Antitrust Compliance – The Antitrust Division’s Subtle Shift Regarding Corporate Compliance: A Step Toward Incentivizing...

INTRODUCTION: A surprising feature of many corporate compliance programs is their limited emphasis on antitrust. Compliance efforts are a key feature of modern corporate governance initiatives, and it stands to reason...more

DOJ’s Pursuit of Individual Liability for Corporate Misconduct: The Yates Memo

Cooperation credit is a critical issue for corporations that become embroiled in investigations or enforcement activity. In both the criminal and civil contexts, it is the only way to mitigate the financial impact of...more

[Webinar] The New Compliance Challenge: Protecting Confidential Assets From Cyber Threats and Malicious Insiders - Nov. 5th,...

The growing prevalence of cyber-security issues and insider breaches has put information security squarely on the agenda for many corporations – and increasingly in the realm of compliance. In this webinar, we discuss these...more

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