Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more
In the securities industry, regulators like to say that the compliance professionals are their “partners.” But every so often, those regulators charge one of their compliance partners with rule violations. The compliance...more
Late Monday, the Department of Justice (DOJ) without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. ...more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
The CFPB published a policy statement in today’s Federal Register to announce that, going forward, it is establishing a new “Compliance Aids” designation for certain Bureau guidance. The policy statement becomes applicable...more
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more
Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more
The Department of Justice Criminal Division revised and shuffled two-year-old guidance to help prosecutors evaluate corporate compliance policies when making charging decisions. Our White Collar, Government & Internal...more
Every Chief Compliance Officer (CCO) and compliance practitioner who thinks about their compliance program one, three or five years down the road is a budding futurist. The Compliance Week 2017 Annual Conference opened this...more
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
While many are no doubt celebrating Cinco de Mayo today, it is also the 66th anniversary of the first foray into space for the US, albeit in a sub-orbital way. It was on this date in 1961, that Navy Commander Alan Shepard was...more
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
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
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
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
Norbert Schemansky died last week. Are you as unfamiliar with that name as I was? I must sheepishly admit I had never heard of him before I read his obituary in the New York Times (NYT). Schemansky was one of the world’s...more
On this day in 1776, members of Congress affixed their signatures to an enlarged copy of the Declaration of Independence. Congress adopted the more poetic Declaration of Independence, drafted by Thomas Jefferson, on July 4....more
The legal profession is transforming itself, especially in the area of compliance. Lawyers are an invaluable part of a compliance program. They provide important perspective and understanding of risk, they help a company to...more
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
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
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
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