News & Analysis as of

Chief Compliance Officers Ethics

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

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

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

Creation of Roundabout and Operationalization of Compliance

by Thomas Fox on

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

How Effective is Your Corporate Compliance Program?

On February 8, the Fraud Section of the United States Department of Justice (DOJ) posted on its website a document entitled “Evaluation of Compliance Programs” (the “Guidance”). This is the first formal guidance issued by the...more

Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV)

by Michael Volkov on

In an unusual move, the Justice Department issued an important document in the dead of night – Evaluation of Corporate Compliance Programs. We have no explanation from the Justice Department for the issuance of this...more

The FCPA Pilot Program Disciplinary Standards (Part II of II)

by Michael Volkov on

Returning to the FCPA Pilot Project requirements for timely and appropriate remediation, the Justice Department added three new elements, one of which reinforces the CCO “independence” requirement. The two other elements for...more

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

by Michael Volkov on

The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a...more

Effective Ethics and Compliance Training

by Thomas Fox on

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Leadership Lessons from Mutiny on the Bounty

by Thomas Fox on

In honor of February and its traditional run up to the Oscars, in my podcast on business leadership, 12 O’Clock High, a podcast on business leadership, I am exploring leadership lessons from Oscar-winning Best Pictures. In...more

External Perception of Your Internal Culture Is a Big Deal: What Uber’s Problems Have Taught Us about Reputation

by NAVEX Global on

Ethics and compliance officers might often feel like your company’s corporate culture gets tied into knots, with so many groups imposing demands on your organization’s behavior. But really, a better turn of phrase here...more

How to Nurture a Speak-Up Culture in the Era of Speak-Up Apps

by NAVEX Global on

If ethics & compliance officers ever needed one more reason to embrace a speak-up culture, here it is: thanks to modern technology, employees are already speaking among themselves more loudly than ever before....more

Doing Compliance in an Economic Downturn

by Thomas Fox on

The city of Houston has seen a multi-year economic downturn from the drop in the price of oil. Every company in the energy space has been required to dramatically cut its work force, including unfortunately, it compliance...more

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

by Michael Volkov on

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

The Difference Between Being Right and Doing Right

by NAVEX Global on

Not long ago I wrote about the Securities and Exchange Commission’s recent enforcement actions against companies that include pretaliation clauses in their employment contracts. I posted the article online, and one compliance...more

What is Your Ethical Culture?

by Thomas Fox on

The indictments last week of executives from Tanaka and Volkswagen roiled many in the business world and ethics and compliance arena. Coming on the heels of the Wells Fargo scandal, one might wonder how corporations can stop...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

5 Trends in Whistleblower Hotlines and Protections to Be Aware of in 2017

by NAVEX Global on

Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more

Focus On Enabling Your People, Not Controlling Them, To Create an Effective Compliance Culture

by JD Supra Perspectives on

When employees of all levels believe in and support policies and standards, that’s when you see real compliance. In-house perspective from NetApp GC, Matt Fawcett....more

The Compliance Oversight Review Committee

by Thomas Fox on

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

The Baker Hughes GeoMarket Ethics and Compliance Committee

by Thomas Fox on

Two of the most common compliance focused committees for public companies are those at the Board level and those which sit between the Chief Compliance Officer (“CCO”) and the Board, usually consisting of very senior...more

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