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

Defining the Duty of the Board of Directors over Compliance Functions

I recently posted a blog article about a document released by the Department of Justice entitled “Evaluation of Compliance Programs.” As the title of the document might suggest, the DOJ release covers a variety of issues it...more

This Week in FCPA-Episode 45-the Compliance is Good for Business Edition [Video]

In this episode, Jay and I have a wide-ranging discussion on why good compliance is good for business. We discuss: 1. LRN Ethics and Compliance Program Effectiveness Report. 2. Ethisphere’s 2017 World’s Most Ethical...more

DOJ Releases Guidance on Compliance Programs

In February 2017, the Fraud Section of the Department of Justice’s Criminal Division published guidance on how it assesses corporate compliance programs. This is the first formal guidance issued by the Fraud Section under the...more

Leadership Lessons from the Movies

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

Building Trust in an Organization as a Step to Operationalizing Compliance

Earlier this week I explored LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report). One of the key findings of the Report was that if there was greater employee trust, the values of ethics...more

2017 EMEA & APAC Culture and Compliance Benchmark Report - Data And Insights To Put To Work In Your Programme Today

NAVEX Global partnered with an independent research agency to investigate how companies headquartered across Europe, Middle East and Africa (EMEA) and Asia Pacific (APAC) develop and execute their ethics and compliance (E&C)...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

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

Everything Compliance-Episode 9, DOJ Evaluation of Corporate Compliance Programs, Part II [Video]

This episode is dedicated to the Justice Department’s Evaluation of Corporate Compliance Programs, which was released in February. In this episode, Jay Rosen and Jonathan Armstrong provide next insight. Listen to last week’s...more

March Preparedness: Inadequate Employee Training May Cause Even the Best Employers to Suffer an Upset

Employers implement employee training programs for a variety of reasons, such as furthering professional development and improving poor performance, ensuring compliance with information security protocols and competence using...more

Startup Culture Seems to Be Missing One Key Ingredient—Culture

Sometimes when I read tales of startups riddled with problems of corporate culture and poor conduct, I want to grab the founders by their shoulders and shout, “You’re doing it wrong!” I suspect I’m not alone among compliance...more

Corporate Compliance Programs: US and UK Perspectives

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

LRN Compliance Program Effectiveness Report: Part III

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

Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV)

We all know that a compliance program without business buy-in is, by definition, an ineffective compliance program. The level of business support ranges from “mouthing” support to full-fledged embrace and ownership of...more

FCPA Compliance Report-Episode 316-Kristy Grant-Hart & a debate on ISO 37001 Certification [Video]

In this episode Kristy Grant-Hart, author of How to be a Wildly Successful Compliance Officer, joins me to debate the merits of the ISO 37001 certification. I think the process is worse than useless while Kristy believes it...more

LRN Compliance Program Effectiveness Report: Part II

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

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

Doing Business in Cuba Under the FCPA

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more

Compliance Report-International Edition, Carlos Ayres [Video]

In this episode i visit with Brazilian compliance practitioner Carlos Ayres on recent developments in Brazil and South America in the ongoing fight against bribery and corruption....more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may...more

Sapin II Law: The new French legal framework for the fight against corruption

Law no. 2016-1691 on transparency, fighting corruption and modernising economic life was published in the Official Gazette on 10 December 2016. Known as the Sapin II Law, its main objective is to set up a genuine...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

Chicago Proposes Pharma Rep Licensing Rules and Ethical Standards

The City of Chicago Commissioner of Public Health on Friday, March 17, published proposed Rules to implement the highly-publicized pharmaceutical representative licensing ordinance enacted in November 2016....more

What Does the "Good News Cocoon" Mean to Business & Compliance?

Recently, I had the pleasure of engaging with compliance and business leaders in Europe and Asia. It’s an honor to be traveling again, and to hear about ethical and compliance challenges from those who work in the middle of...more

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