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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DOJ and SEC Officials Focus on Enforcement, Self-Reporting and Compliance at International FCPA Conference

From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more

Shoring Up Your Internal Controls to Keep Your FCPA Compliance Program Current

We recently hosted a webinar featuring noted FCPA expert Tom Fox. Tom explained exactly what the DOJ and SEC look for when enforcing the FCPA and how organizations can stay within the FCPA regulations. Jimmy Lin, our VP of...more

How to Avoid a Mousetrap – Resource Reductions in Your Compliance Function

On this day, 62 years ago, “The Mousetrap”, a murder-mystery written by Agatha Christie, opened at the Ambassadors Theatre in London. The crowd-pleasing whodunit has become the longest continuously running play in history,...more

The FCPA Guidance: Still Going Strong at Two

One of the great things about Sunday afternoon is that Mike Volkov posts his Monday blog, when I usually have time to read it when I get the email notification that it is up. Yesterday he wished the Department of Justice’s...more

Anti-Bribery and FCPA Compliance Guide for U.S. Companies Doing Business In India

The U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”) presents significant liability, risks, and compliance challenges for U.S. firms pursuing business opportunities in India. U.S. regulators have brought numerous...more

Changing Regulatory Regime Necessitates New Solutions To An Old Problem: 5 Elements Critical To An Anti-Fraud Compliance Program

US government regulators have become more aggressive in their detection and enforcement of fraud against the government. One of the key tools they are using to combat such fraud is the False Claims Act. Most FCA cases are...more

The Strategic Use of Compliance

What is your company’s compliance strategy? By this I do not mean what is your company doing to put in a place a best practices anti-corruption compliance program that meets the requirement of the Foreign Corrupt Practices...more

FCPA Compliance and Ethics Report-Episode 108-Supply Chain Under the FCPA [Video]

In this episode I discuss several different risk based models to evaluate your supply chain under the FCPA or UK Bribery Act. ...more

A Holistic Look at Third Party Risks

In the FCPA world, we tend to get myopic. We see complex issues and business operations through the prism of anti-corruption risks. Businesses and Chief Compliance Officers, however, have a very different perspective....more

Chamber of Commerce: Corporations Form the Cornerstone of FCPA Compliance

Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement. You may be surprised to find...more

Opinion Release 14-02: Dis-Linking The Illegal Conduct Going Forward

One of my favorite words in the context of Foreign Corrupt Practices Act (FCPA) enforcement is dis-link. I find it a useful adjective in explaining how certain conduct by a company must be separated from the winning of...more

Atlanta Burns – the Bio-Rad FCPA Enforcement Action – Part III

On this date in 1864, the Union Army phase of the destruction of Atlanta began. While most Southerners credit Union General William T. Sherman with the burning of Atlanta, it was, in reality, Confederate General John Bell...more

The Curious World of the Antitrust Division and Credit for Compliance Programs

The Antitrust Division is a world unto itself. Ask anyone who works there (including me) or worked there and they will tell you that everyone refers to the Antitrust Division as “The Division,” like it is the only Division in...more

OCEG Interview: Connecting Compliance Training To Other GRC Components, Like Policy Management Systems

In a recent interview, OCEG‘s Scott Mitchell discusses integrating your compliance training with the entirety of your GRC program (such as your policy management system and whistleblower hotline) with The Network’s Jimmy Lin,...more

Prevent Financial Misconduct Before it Begins: Five Steps to Building an Effective Business Conduct Programme in the U.K.

In the third of three posts on the future enforcement of U.K. financial crimes, we explore how to prevent misconduct before it begins by implementing an effective business conduct programme... Each of the four trends...more

Don’t Collapse in the Wind – Knowledge is Power

On November 7, 1940, high winds buffeted the Tacoma Narrows Bridge leading to its collapse. The first failure came at about 11 a.m., when concrete dropped from the road surface. Just minutes later, a 600-foot section of the...more

A CCO’s Vision Needs to Include “Line of Sight”

With the rise of chief compliance officers, come new terms and concepts. That is a good thing because it represents a maturation and standardization of the profession....more

Tribute to Jack Bruce – Finding Talent to Support Your Compliance Function

Jack Bruce died last week. He was simply one of the greatest rock and roll bassist of all-time, as in ever. He helped form Rock’s first super group Cream when he joined with guitarist Eric Clapton and drummer Ginger Baker to...more

Sharing the Spotlight: M&A Due Diligence

Everyone likes to talk about the importance of due diligence. A whole new due diligence industry has grown, starting with initial anti-money laundering requirements and stretching into corruption and sanctions issues....more

Giants Join Pantheon of Greats Through the Confluence of Culture and Strategy

Last week the San Francisco Giants won their third World Series championship in five years. This elevates them into the conversation of the Pantheon of elite teams over the past 50 years. Only the New York Yankees (1998-2000)...more

MSRB Creates Supervision and Compliance Requirements for Municipal Advisors

On October 23, the Municipal Securities Rulemaking Board received approval from the SEC to create the first new rule for municipal advisors since the SEC released its final registration rule for these professionals in...more

FCPA Compliance and Ethics Report-Episode 102-interview with Bruce Carton [Video]

In this interview I visit with Bruce Carton, founder and editor of Securities Docket. We discuss the recently concluded 2014 Securities Enforcement Forum; its panels, discussions and vibe. ...more

Safety and Soundness Versus CRA: Walking a Tightwire

I was just reviewing the proposed CRA FAQs again (yes, that makes me a compliance nerd) and I was struck anew by the tension between lending programs that are designed for LMI markets and the requirements for safe and sound...more

FCPA Compliance and Ethics Report-Episode 101-interview with Chris Bauer [Video]

In this episode 101 of the Compliance and Ethics Report, I visit with Chris Bauer. Chris is a well-known ethicist who speaks, writes, lectures and teaches about ethics in business. ...more

TCPA Best Practices: Consent, Compliance, Communication

SUTHERLAND’S THREE C'S: CONSENT, COMPLIANCE, COMMUNICATION - What is the TCPA? The Telephone Consumer Protection Act of 1991 (TCPA) protects consumers from unwanted telemarketing calls, prerecorded or autodialed...more

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