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Compliance CCO

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. ... 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 -
NAVEX

From Healthcare Sector, a Big Push for CCO Autonomy

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For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more

Society of Corporate Compliance and Ethics...

Navigating CCO liability risks: Tips for staying out of the SEC's crosshairs

The issue of chief compliance officer (CCO) liability has long been debated; it has become a grave concern for CCOs, CEOs, and other C-suite executives who put on “too many hats” within an organization and take on the firm’s...more

Harris Beach PLLC

Two Executives and Distributor Charged for Unlawfully Distributing Controlled Substances

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Rochester Drug Co-Operative, Inc. (“RDC”), one of the 10 largest pharmaceutical distributors in the United States, was recently charged along with its former Chief Executive Officer and former Chief Compliance Officer, for...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation Of Corporate Compliance Programs – Guidance Document: Part I – Introduction

As I noted in yesterday’s blog post, at the Ethics and Compliance Initiative (ECI) Impact 2019 Conference, Assistant Attorney General Brian Benczkowski announced (ECI speech) an update to the 2017 Evaluation of Corporate...more

Dechert LLP

Fund Boards May Rely on CCO Representations in Lieu of Quarterly Board Determinations Under Rules 10f-3, 17a-7 and 17e-1

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The Staff of the SEC’s Division of Investment Management has issued a no-action letter permitting a fund’s board to rely on written representations from the fund’s CCO in lieu of quarterly determinations that the fund’s...more

Thomas Fox - Compliance Evangelist

Lincoln and Transformative Leadership – Part II

When faced with a compliance issue or an obstacle you should endeavor to keep everything on an even keel and never let them see you sweat. ...more

The Volkov Law Group

No More Excuses: CCOs Have to Embrace Technology

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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

The Volkov Law Group

The Power of Honesty – A Candid Assessment of Your Compliance Program

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The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made.  Groucho Marx - We are all taught the importance of honesty. But there are very different aspects to this otherwise simple...more

Thomas Fox - Compliance Evangelist

Compliance Expertise Needed on the Board

This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more

The Volkov Law Group

Hiding Behind the Privilege – A Cloak or a Dagger?

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CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the...more

NAVEX

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

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Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

NAVEX

[Webinar] 2016 Ethics & Compliance Virtual Conference - Harnessing the Business Value of an Ethical Culture - November 15th,...

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Join professionals in ethics and compliance, human resources, legal, audit and training for the annual 2016 Ethics & Compliance Virtual Conference! Learn strategies to help you build a better governed, more risk-aware, and...more

McGuireWoods LLP

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

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On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more

NAVEX

Top Ten Resources for Engaging Your Board in Your Ethics & Compliance Program

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Resources to help you engage your board of directors in the success of your ethics and compliance program. A successful board engagement strategy can help ethics and compliance professionals gain significant program...more

Dechert LLP

SEC Issues Settled Enforcement Action Against Investment Adviser, its President and Senior Officers for Compliance Program...

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The U.S. Securities and Exchange Commission (SEC or Commission) issued a cease and desist order (Order) on June 23, 2015, against Pekin Singer Strauss Asset Management Inc. (Adviser), an investment adviser registered under...more

Thomas Fox - Compliance Evangelist

Senn Interview, Part I – Investigations Under the FCPA

One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more

Thomas Fox - Compliance Evangelist

Leadership Lessons for the Compliance Practitioner from Abraham Lincoln

The recent film about Abraham Lincoln has focused the nation’s attention once again on the President that many believe was our greatest President. In a recent article in the New York Times (NYT), entitled “Lincoln’s School of...more

Thomas Fox - Compliance Evangelist

Leadership in the Compliance Function – Do You Encourage or Stifle?

There are many ways for a Chief Compliance Officer (CCO) to exercise leadership in not only the compliance function but also across the many disciplines in which compliance impacts in any corporation. In this Sunday’s New...more

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