Compliance Anti-Corruption

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

The Importance of Risk Ranking to Compliance

We all face a number of risks every day. Yet, we do not respond to each and every risk. We engage in risk-ranking our responses. Some are more risk than others and some are more catastrophic than others. So, we engage in risk...more

VW: The Challenge of Whistleblowing

The following guest post is by Wendy Addison. A hand shot up from the lecture hall: ‘I don’t understand’, a young economics undergraduate said, looking perplexed, ‘surely a company’s executives would want to know...more

The Terrain of Global Anti-Bribery Compliance Challenges [Video]

In the second part of their interview, Alison Taylor, Director of advisory services at BSR, a non-profit consultancy and company network focused on sustainability and CSR, and James Cohen, an expert on anti-corruption,...more

India Supreme Court Clarifies Standard for Enforcement of Indian Prevention of Corruption Act

Earlier this year, the Supreme Court of India clarified the standard necessary to prove violations of India’s Prevention of Corruption Act, 1988 (“PCA”), in a ruling that may limit enforcement of the PCA and that has...more

Innovation in Compliance – Part III: Design Thinking

I continue to explore innovation in the compliance function by considering how design thinking can help the Chief Compliance Officer (CCO) move forward in an innovative cutting edge manner to make a compliance program not...more

SEC Adopts New Rules Requiring Disclosure of Resource Extraction Payments

On June 27, 2016, the Securities and Exchange Commission (SEC) adopted new rules requiring certain producers of oil, natural gas and minerals to publicly disclose information regarding payments to the U.S. federal government,...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

Global Trends and Business Ethics

The following is part one of a two-part guest post by Alison Taylor and James Cohen. 2016 is only half-complete, but it’s already been a pivotal year in ethics and compliance. The Panama Papers and Unaoil data leaks...more

Battle of the Somme Week – Part V: What did it all mean?

Today, July 1 is the 100th anniversary of the first day of the Battle of the Somme. As I have written this week, there is no single battle in modern British history that has made a greater impression on the British psyche....more

Compliance Training – Part II: Risk Ranking and Design

Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and...more

Be Fully Compliant, and Avoid Lawsuits!

Who could dislike the title of this post? It promises to solve all your compliance problems and keep your business out of litigation. Were it only that simple. Of course, it is not. But, when it comes to compliance,...more

Lie to Win or Be Honest and Lose? When Ethics Can Cost You

What would you do? In this classic situation, all the elements for staying the course rather than disclosing the truth are present and the question is: should you tell on yourself? Ellen Hunt sets forth the dilemma that we...more

Can you teach anti-corruption?

The following interview is with Elena Helmer, Director, Master in Anti-Corruption Studies (MACS) Programme, International Anti-Corruption Academy (IACA). Q: Elena, you are director of IACA’s Master in Anti-Corruption...more

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

Corruption Risks and Corporate Social Responsibility Spending

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

Up Close and Personal: Individual CCO Liability – Part I

A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV...more

Joe Howell on the PCAOB, Audits and Compliance – Part II

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell...more

Joe Howell on the PCAOB, Audits and Compliance – Part I

I recently had the chance to visit with Joe Howell, the Executive Vice President (EVP) of Workiva LLC. Howell has been the Chief Financial Officer (CFO) of a number of public companies, mostly in the technology space, and...more

The Pen is Mightier than the Compliance Sword

Nicole Rose brings a breath of fresh air to compliance. 6 years ago she swapped her legal practicing certificate for her pen and has been thriving ever since. She founded Create Training almost 3 years ago, and over this...more

Top Ten International Anti-Corruption Developments for April 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

FCPA (and my) Failure

I haven’t thought too much about failure lately, until I read Roy Snell’s piece, “We Are All Victims…Except Richard Bistrong.” Roy’s article took me by surprise, as his blog piece addresses a primary foundation of my work:...more

What is a Compliance Evangelist?

What does it mean to be the Compliance Evangelist? A colleague put that question to me last week. This friend is a loyal and long time reader of my blog and listener of my podcast and I thought if it was not clear to her,...more

Panama Papers Scandal Puts Third Party Risk in Focus

The Panama Papers scandal should serve as a wake-up call for every organization—and it should prompt compliance officers to closely scrutinize the third party vendors they do business with. ...more

Panel Offers Insights on Doing Business in Colombia

As Colombia moves toward a peace agreement with FARC rebels and works to accomplish reforms necessary for OECD accession, the nation stands poised at the threshold of significant growth and transformation. Such was the...more

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