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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 -

In the Third-Largest FCPA Enforcement Action Ever, Telia Agrees to Pay Almost $1 Billion to Resolve Bribery Inquiry in Uzbekistan;...

by Ropes & Gray LLP on

In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the U.S. Department of Justice (“DOJ”) and...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

Moving Back In-House to Move Compliance to the Next Generation

The following interview is with Nicole Rose, Head of Risk and Compliance, Uniting Resources NSW and ACT. As you may recall, Nicole and I co-produced the anti-bribery training animation, “Why We Say Yes,”. RB: So, Nicole, I...more

SEC Issues Risk Alert on the Most Frequent Advertising Rule Compliance Issues and Use of Accolades in Advertisements

by Proskauer Rose LLP on

I. Advertising Rule Compliance Issues - On September 14, 2017, the staff of the SEC's Office of Compliance Inspections and Examinations (OCIE) issued a National Examination Program Risk Alert on the most frequent advertising...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Day 15 of One Month of Innovation in Compliance-Structural Innovation

by Thomas Fox on

Innovation can come in various forms for an organization. Innovation can appear in a structural form. You can move compliance more deeply into your organization with new or different structures. One I have seen have success...more

Compliance Training Lessons From Utah, Caught on Tape

by NAVEX Global on

For a while now, I’ve been contemplating ethics and compliance lessons from the arrest of Alex Wubbels— the Utah nurse taken into custody by Salt Lake City police, because she refused to draw blood for an unconscious patient....more

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

Day 14 of Innovation in Compliance-Putting Compliance at the Center of Business Strategy

by Thomas Fox on

Another innovation is to put your compliance program at the center of corporate strategy. An article in the Harvard Business Review (HBR) by Frank Cespedes, entitled “Putting Sales at the Center of Strategy”, discussed how to...more

Australia Proposes Modern Slavery Reporting Requirements for Multinationals – An Overview and Comparison to Existing Corporate...

by Ropes & Gray LLP on

The Australian Government has released a consultation paper proposing the adoption of legislation that would require many multinationals operating in Australia to publicly report on modern slavery risk in their business and...more

No More Excuses: CCOs Have to Embrace Technology

by Michael Volkov on

It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more

Criminal justice: How best to stop economic crime

by WilmerHale on

Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more

3 Pillars to Measuring Compliance Program Effectiveness

by NAVEX Global on

Compliance leaders across industries are focused on assessing and enhancing their compliance effectiveness in response to regulatory requirements and expectations. This includes ensuring that they have a strong compliance...more

Farewell to a Repo Man and Using Laconic Persuasion as a CCO

by Thomas Fox on

The life of a Repo Man is always intense… That was one of the greatest lines from one of the greatest movies from one of the greatest laconic actors of all time. Of course it was Harry Dean Stanton who died over the...more

Day 10 Of Innovation in Compliance-Improvisation in Compliance

by Thomas Fox on

How can you change the perceptions around compliance in your organization? With the Justice Department requirement, set out in the Evaluation of Corporate Compliance Programs, to more fully operationalize your compliance...more

China’s ‘One Belt, One Road’ Initiative Creates Opportunities and Regulatory Challenges

In a time of shifting opinions on the benefits of globalization, China’s “One Belt, One Road” initiative (OBOR) offers an unexpected bright spot for multinational companies able and willing to participate in this...more

Compliance into the Weeds-Episode 54, Report from TEC 2017

by Thomas Fox on

In this episode, Matt Kelly returns to his journalism roots with a live report from TEC 2017, the Workiva user conference. We discuss some of the hot topics at the conference including possible repeal or modification of SOX...more

The Financial Report, Vol. 6, No. 17

by DLA Piper on

The juxtaposition of items in the financial news is always fascinating. Earlier this week, an article appearing in the Wall Street Journal stated that state legislatures are moving to bolster investor protections due to...more

4 Signs of a Poor Relationship Between a CCO and the Board

by Michael Volkov on

Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more

Day 12 of One Month of Innovation in Compliance-Real Time v. Right Time Monitoring

by Thomas Fox on

If it is not clear already this month, innovation does not simply come from a technical or even service perspective but can improve your compliance program from a wide variety of perspectives. We have considered a variety of...more

Compliance Man Goes Global-Episode 1

by Thomas Fox on

I welcome you to a new series entitled Compliance Man Goes Global podcast of Compliance Report-International Edition. I am joined by Tim Khasanov-Batirov, a compliance practitioner who focuses on high risk markets for 17...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

Day 11 of One Month of Innovation in Compliance-OODA Feedback Loop

by Thomas Fox on

Alistair Croll draws on military theory to illustrate his concept of a feedback loop. It is the OODA loop, which stands for observe, orient, decide and act. This comes from military strategist John Boyd who realized that...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

by Foley & Lardner LLP on

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

Behavioral Ethics & Just-in-Time Compliance Communications

by NAVEX Global on

Timing is everything. At least, that is part of the learning from several experiments described in a Harvard Business School Working Paper - “When to Sign on the Dotted Line: Signing First Makes Ethics Salient and Decreases...more

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