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Chief Compliance Officers Corporate Culture White Collar Crimes

The Volkov Law Group

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review

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How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

DLA Piper

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

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On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 5 – CCOs Using Town Halls to Build Compliance

This week we have been exploring how Chief Executive Officers and other senior executives can set an appropriate Tone at the Top by actually walking-the-walk of compliance rather than simply talking-the-talk of compliance....more

Society of Corporate Compliance and Ethics...

Overcoming Internal Barriers to Compliance Success

Compliance professionals can face a lot of resistance in the course of their work: leaders who don’t have the time, budget limits, managerial indifference, and even outright hostility. But, sometimes the impediments are...more

The Volkov Law Group

Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report

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LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael...more

The Volkov Law Group

The Evolution of the Compliance Profession

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One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

Society of Corporate Compliance and Ethics...

Branding Your Compliance Program

You may not realize it, but your compliance program has a brand. Line employees and management all have a host of impressions about the compliance department that color how they respond to what you say and do. A strong brand...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

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Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

The Volkov Law Group

Building a Compliance Dashboard (Part I of II)

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This is a topic that every compliance professional has to address in one form or another.  Chief compliance officers are so busy that they often cannot even take the time to tackle this difficult issue.  This is a real...more

The Volkov Law Group

Where Does Your Compliance Program and CCO Fall Under DOJ’s Independence, Authority and Resources Test? (Part IV of IV)

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As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance...more

The Volkov Law Group

The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV)

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There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics...more

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

Jenner & Block

DOJ Initiatives Aim to Empower Chief Compliance Officers and Strengthen Corporate Compliance Programs

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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

The Volkov Law Group

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

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Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

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On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

The Volkov Law Group

Insights from Recent NAVEX Global and KPMG Surveys

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Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

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“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

The Volkov Law Group

Measuring and Reporting on the Organization’s Culture (Part III of IV)

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While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more

The Volkov Law Group

When a CCO Fails to Speak Up

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We often discuss the importance of a “Speak Up” culture.  We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization....more

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

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Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

The Volkov Law Group

CCOs and Expertise in Risk Management

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Chief compliance officers (CCOs) are talented professionals.  As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation.  CCOs focus on legal and compliance risks...more

The Volkov Law Group

Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III)

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While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more

The Volkov Law Group

Admit It – Your Compliance Program is Not Really “Effective”

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Chief compliance officers are heroes.  They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

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The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

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