Compliance Chief Compliance Officers

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 -
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Mickey Rooney And The 90 Cent Solution

We begin today with a word on the death of Mickey Rooney. Rooney’s career, spanning nearly 90 years was certainly was from a different era. He was short of stature and long in his number of marriages but as Bob Lefsetz noted...more

Ketchum Shares Bon Mots with BD Industry at SIFMA Meeting

At this week’s Annual SIFMA Law and Compliance meeting, FINRA CEO Rick Ketchum provided a number of candid and pointed comments in a wide-ranging and no-holds-barred interview conducted by long-time senior compliance official...more

The Battle Of Shiloh, Corruption In Ukraine And Things To Come

On this day 126 years ago the two-day battle of Shiloh ended. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely...more

Do Compliance Professionals Have To Be Lawyers?

As compliance professionals enjoy the rise of their profession, lawyers are sensing a decline in importance. I am hearing from compliance professionals a new and disturbing trend – companies are requiring compliance...more

Dodd-Frank Compliance in a Nutshell

Here are some important Dodd-Frank rules that you need to keep in mind if you are neither a Swap Dealer nor a Major Swap Participant ("Non-SD/MSP"). Clearing - General Rule. Dodd-Frank requires all swaps listed...more

CCO’s Be Careful What You Ask For — You Just May Have It

The old adage has taken hold in the compliance field – “Be careful what you ask for, you just may get it.” Compliance professionals are finally getting the respect they deserve. They still have a long way to go. ...more

Anti-Corruption Digest - March 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Tales From The Crypt - Rule 6: Never Mix Business With Pleasure

Ed. Note-this week on am on a Spring Break college tour with my daughter. The Two Tough Cookies whom are penning the Tales From the Crypt Series have graciously agreed to contribute a week’s worth of workplace Tales from...more

Encouraging Communication Of Employee Concerns

One of the hardest issues for compliance professionals is encouraging employees to raise concerns about ethics and compliance issues. It has become even more difficult when the government establishes whistleblower programs...more

Common Mistakes, Problems And Concerns Companies Face During Implementation And Maintenance Of Corporate Compliance Programs

An effective corporate compliance program is an essential component of internal controls for uncovering and preventing ethical lapses and criminal violations and smart companies are prudently adopting these programs. However,...more

Keeping Compliance Focus On Risky Interactions

People who consistently miss the point are frustrating. Focus is an important discipline. Whatever you do in life, the ability to focus is critical....more

Best Practices For Anti-Corruption Compliance Programs – A Moving Target

The Justice Department and the SEC have pushed extraordinary changes in the field of anti-corruption compliance. If one looks back five years ago and compares the so-called best-practices from 2008 and compares them to...more

FINRA Sanctions Firm And Compliance Officer For AML Violations

This past February, FINRA issued an acceptance, waiver and consent (“AWC”) against a firm and its global anti-money laundering (“AML”) Compliance Officer (“CO”) for failures in AML compliance regarding brokerage and custodial...more

The Cost Of Compliance

The title for this posting is a little ambiguous. What is the “cost” of compliance? Is it the cost of implementing an “effective” compliance program? Or is the “cost” to the company of an “ineffective” compliance program. ...more

3 Basic Steps to Improving the Effectiveness of Anti-Bribery Training

To say anti-bribery training is important is one huge understatement. It continues to be one of the key elements in any effective or any best practices compliance program. The US Sentencing Guidelines contains clear language:...more

Miners Triumph And Opinion Release 14-01

On this date in 1966, the Texas Western University (now UTEP) Miners won the NCAA Basketball Championship, beating the University of Kentucky Wildcats. Now the first round has not even started by March 19, but it is not the...more

Interviewing in the Context of Workplace Investigations

As an ethics and compliance professional and investigator, I have been intrigued by the recent media coverage of wrongful convictions. Also, the stories reminded me of a fascinating article in the New Yorker magazine a few...more

Survey: 28 Reasons Why The Typical Compliance Officer’s Week Leaves Dangerously Little Time for Corporate Ethics Training

I just downloaded and read the annual Cost of Compliance survey compiled by Thomson Reuters Accelus. It’s very interesting reading for those of us in the ethics and compliance industry. In my last blog post about the ERC...more

Are Internal Compliance Investigations Privileged? D.C. District Court Rules No

U.S. District Court for the District of Columbia holds documents related to internal investigations of possible violations of corporate code of conduct not protected from disclosure under either attorney-client privilege or...more

The Ides Of March And Evaluation Of Compliance Risk

Tomorrow, March 15 is enshrined as one of the most famous days of all-time, the “Ides of March”. On this day in 44 BC, the “Dictator for Life” Julius Caesar was assassinated by a group of Roman nobleman who did not want...more

Compliance Program Success: “Doing Better With Less”

Chief Compliance Officers always are asked to do more with less. It is a simple and overused phrase, usually promoted by corporate bean counters looking for ways to justify decisions that serve their own financial interests....more

FDR’s Fireside Chat And Risk Ranking Of Third Parties Under The FCPA

On this date in 1933, just eight days after he was inaugurated, President Franklin Roosevelt (FDR) gave his first Fireside Chat to the American public. FDR began his chat by stating, “I want to talk for a few minutes with the...more

Compliance Leadership Lessons From Captain Kirk

As readers of this blog know, I am an über Star Trek maven. Last week, in Episode 41 of my podcast, the FCPA Compliance and Ethics Report, I visited with John Champion, one of the co-hosts of the Mission Log podcast....more

Machiavelli For Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince by Niccolò Machiavelli. Just how evil do many people view the treatise? Consider that...more

Startling ERC Survey Findings on Misconduct, Retaliation – Is Your Corporate Ethics Training Working?

Last spring I was speaking with several of our clients at an event in Atlanta and the discussion was around ethics and compliance program effectiveness. Specifically, these clients were saying that more and more often they...more

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