Compliance

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
News & Analysis as of

Does the SEC Want Issuers to Self-Report Everything?

Andrew Ceresney, Director, SEC Division of Enforcement delivered remarks at a conference where he addressed the SEC’s cooperation program. Much of the focus was on the benefits of self-reporting and cooperation in...more

Compliance Week 2015 Wrap Up

Compliance Week 2015 has ended. This year was the tenth anniversary of the annual conference and in many ways I found it to be the best one yet. Matt Kelly and his team put together a conference and experience, which was...more

FCPA Compliance and Ethics Report-Episode 160-Compliance Week 2015 Wrap Up with Mike Volkov and Jay Rosen [Video]

In this episode, Jay Rosen and Mike Volkov help me to wrap up the Compliance Week 2015 conference which just concluded in Washington DC. ...more

[Webinar] Mid-Sized Companies and Anti-Corruption: How to manage corruption risks with limited resources - May 28, 11:00 am EST

Instances of corruption can have a significant impact on a company’s finances and reputation. With international anti-bribery enforcement actions on the rise, it is essential for companies to implement an anti-corruption risk...more

Preventing the Worst: Stopping Obvious and Bold FCPA Violations by Executives

Last year, a number of corruption cases, both individual prosecutions and suits against companies, revolved around the behavior of senior executives. While third parties can often be the vehicle companies use to funnel bribe...more

[Event] Ethics & Compliance Exchange 2015 – June 11, Chicago, Illinois

Things are changing fast in the worlds of governance, risk management and compliance. With each day comes bigger corporate risks and the consequences of not seeing them coming. Companies are beginning to embrace “breaking...more

Levi Strauss and Auditing of Third Parties

Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

Why Reputation Risk is Quickly Climbing the Ethics and Compliance Priority List, Part 3 | Beyond Compliance Training

So far in this series, we’ve discussed why companies are adopting a more public focus on ethics and compliance, how reputational risk can impact a company and its brand, and the first three elements of a five-part framework...more

A CCO Job Function: Managing Talent

Garo Yepremian died this past week. For anyone who grew up watching National Football League (NFL) games in the late 1960s or 1970s; this was a name quite familiar to you even if you had trouble pronouncing it. Yepremian was...more

Cybersecurity Oversight: What is a Board of Directors to Do?

Cybersecurity and the risks of data breaches figured prominently at the 35th Annual Ray Garrett Corporate and Securities Law Institute held April 30, 2015, at Northwestern Law School in Chicago. Participating in a panel...more

FINRA’s Revised Sanction Guidelines: Higher, Tougher, Fairer?

FINRA’s newly revised Sanction Guidelines, effective immediately, signal that the upward trend in sanctions against broker-dealers is likely to continue. The Sanction Guidelines, which establish the range of sanctions...more

FCPA Compliance and Ethics Report-Episode 159-Alison Taylor on the intersection of CSR and the FCPA [Video]

In this episode I visit with Alison Taylor of BSR about the organizational behavior issues around bribery and corruption and the intersection of Corporate Social Responsibility and the FCPA. ...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

The Thrill is Gone: On the Intersection of CSR and the FCPA

Somehow it seems fitting that the legacy of BB King inform today’s blog post which is about the intersection of Corporate Social Responsibility (CSR) and anti-corruption laws such as the US Foreign Corrupt Practices Act...more

I Was An Irrational Compliance Calculator

In what might be described as a “companion guide” to my Ethikos article Does Compliance Need More “Darkside,” I had a chance to read Scott Killingsworth’s work in the same edition, The Irrational Calculator: Sales at the...more

The Recent SEC Attack on Confidentiality Agreements: What Employers Need To Know and Do Now

Introduction - • Employers typically impose confidentiality restrictions to protect trade secrets and confidential information, including when conducting internal investigations and in employee separation...more

Why Reputation Risk is Quickly Climbing the Ethics and Compliance Priority List, Part 2 | Beyond Compliance Training

Last week, we covered the fundamentals of how reputational risk can impact a company. More companies are crafting strategies to handle this level of brand management by incorporating a more public focus on ethics and...more

Multiple Departments Issue Guidance on Wellness Programs

The Equal Employment Opportunity Commission (EEOC) made headlines during the second half of 2014 by attacking employers' wellness programs that require employees to undergo certain medical testing or be penalized. In three...more

Oklahoma Firefighters Pension & Ret. Sys. v. Citigroup Inc., C.A. No. 9587-ML (VCN) (Del. Apr. 24, 2015) (Noble, V.C.)

In this memorandum opinion, the Court denied the exceptions of defendant Citigroup Inc. (“Citigroup” or the “Company”) to the Master’s Final Report and adopted the recommendations therein related to a demand to inspect the...more

[Webinar] Compliance Agility: Managing Privacy in a Dynamic Environment - June 9, 1:00-2:00 pm Eastern

Privacy risk, legislation, and regulation is growing at an exponential rate. Organizations – themselves in constant states of change – are struggling to keep up and fearful because a single organizational change, be it...more

EEOC Issues Long-Awaited Proposed Rule on Employer Wellness Programs

On April 18, 2015, the Equal Employment Opportunity Commission (EEOC) issued a proposed rule on the treatment of employer wellness programs under the Americans with Disabilities Act (ADA). The proposed rule amends the ADA...more

FCPA Compliance and Ethics Report-Episode 158-Jeff Lurie on pre-acquisition M&A protocols [Video]

In this episode I visit with management consultant Jeff Lurie about his thought for your pre-acquisition protocol when evaluating a company for a merger or acquisition...more

"HHS OIG Issues New Compliance Oversight Guidance for Boards of Directors"

On April 20, 2015, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published its “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the Guidance).1...more

Benchmarking Your Hotline in 2015: How Does Your Data Measure Up?

Ethics officers agree—one of the most effective ways to measure your compliance program is by analyzing data from internal reporting systems. But how can you know what is good or bad without context? We compiled 2014...more

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