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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Manufacturing Matters - Winter 2016

Welcome to Manufacturing Matters, DLA Piper’s specialist publication providing a round-up of legal news, sector updates and commentary for clients and contacts engaged in the manufacturing sector. British manufacturers...more

Communicating Culture Outside the US – Part 2

Yesterday, I began an exploration about some of the issues around communicating corporate culture to business units located outside the US and away from the corporate office. This series is based on a recent article in the...more

Tribute to Sam Spence and Management?Leadership

Sam Spence died last week. His was not a name that many folks were aware of generally and even in the sports world where he made his greatest mark. Yet he was a prime mover in the explosion of growth by the National Football...more

Embedding the Compliance Message in Middle Management

Chief compliance officers and senior executives wrestle with strategies to spread and embed important compliance messages. A CEO and senior executives can spread a compliance message but they are always battling competing...more

What Good Compliance Looks Like: Part III

I concluded Part II of “What Good Compliance Looks Like” with “compliance and tone at the top are more than stated values, it’s about operational and unspoken values. It’s about a seat at the table of business strategy.”...more

Rubik’s Cube and the Intersections of Compliance

It is generally believed that the world’s single best selling toy is the Rubik’s Cube, invented in 1974 by the Hungarian Erno Rubik. Although it was initially believed that Rubik’s Cube was built as a teaching tool to help...more

Tribute to the Jefferson Airplane and Communications in Compliance

There are times when the universe converges in some of the oddest coincidences. It happened one day last week when two members of the original Jefferson Airplane lineup died on the same day. Most people familiar with what my...more

Data Analytics Week – Part IV: Third Parties and Duplicate Invoices

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Data Analysis Week – Part III: Data Analysis to Prevent Employee Fraud

I continue my exploration of the use of data analytics in a best practices compliance program. Today we look at how data analytics can be used to help detect or prevent bribery and corruption where the primary sales force...more

Data Analysis Week – Part I: What is Data Analysis in Compliance?

This week I will begin a five-series exploring data analysis and how it can be used by the Chief Compliance Officer (CCO) or compliance practitioner to support a best practices compliance program under the Foreign Corrupt...more

Take It Easy – Ruminations on Corruption Scandals in International Sports

As I end my week’s exploration of the intersection of bribery and corruption in international sports, I have also ended a week of solid listening to The Eagles 1970s studio albums. In honor of Glenn Frey, I will also end this...more

Fraud and Bribery: Segregation of Duties

Some things go together. Chocolate chip cookies and milk, Hepburn and Tracy, Lewis and Martin (I know, I am showing my age, but you get the point), and many other favorite combinations. So, you get the point – in the world of...more

How the Venetian Gondolier Informs Your Compliance Program

This is my final Travel Edition from Venice. If there is one thing that is ubiquitous throughout this city it is the Gondolier, the Venetian Gondola boatman. You are never far from hearing their cry of “Gondola, Gondola” to...more

The Four Seasons and Structure in Your Compliance Program

I return to my Travel Edition themed blog posts today. One of Venice’s greatest citizens was Antonio Vivaldi. His work is celebrated throughout his home city. Last night, I saw a performance of his most famous work, The Four...more

Cyber Security Compliance: The Role of the CCO

For years, cyber security has been the province of IT specialist and technicians. Those days are long gone. If you ask a Board of Directors to identify a company’s most significant risk – cyber security is tops....more

The Year 2016 in Compliance

Greetings from Venice where my wife and I are spending the next few days so this blog post is my first Travel Edition of 2016. Last week I wrote about my thoughts on some of the significant Foreign Corrupt Practices Act...more

What Does Good Compliance Look Like?

At a corporate summit, the CEO of a Fortune 500 company started his talk by asking “what does good look like?” Good question. “Rules often inspire legalism and minimalism,” he said. “But they don’t govern behavior.” He...more

Building and Managing the Right Team for Compliance

On this date in 1929, Walter Chrysler was announced as Time Magazine’s Man of the Year. Chrysler was a seminal figure in the American automobile industry in the last century and in business leadership. He grew his company to...more

Ethics and Compliance Predictions for 2016

The New Year brings new promise for compliance professionals. I always sympathize with compliance officers because of their inevitable conflict – their idealism often is confronted by corporate realities – a CEO who...more

The Father of Texas and Leadership in Compliance

Today we celebrate leadership, which comes from a different place than we usually see. On December 27, 1836, the Father of Texas, Stephen F. Austin, died. Most people think Sam Houston was the father of this great state but...more

Four Compliance Trends and Challenges for 2016

As we close out the year, it is now time to begin the retrospective reviews and predictions for the New Year. I will try to keep them to a minimum but I find it important to reflect and look forward to new challenges....more

SEC Enforcement Chief Andrew Ceresney Discusses CCO Liability

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

Applying Practical Strategies to Supply Chain Risk

Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball and...more

Due Diligence and Beyond — Balancing Competing Priorities

DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance but I would not characterize this year as limited to third party due...more

Defining Compliance 2.0: The CCO (Part 3 of 5)

These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the...more

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