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 -
News & Analysis as of

The Difference Between Being Right and Doing Right

Not long ago I wrote about the Securities and Exchange Commission’s recent enforcement actions against companies that include pretaliation clauses in their employment contracts. I posted the article online, and one compliance...more

What is Your Ethical Culture?

The indictments last week of executives from Tanaka and Volkswagen roiled many in the business world and ethics and compliance arena. Coming on the heels of the Wells Fargo scandal, one might wonder how corporations can stop...more

The Real Explanation for the Record Year for FCPA Enforcement

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

Honey, I Think We Should Vacation at Home This Year

That may well be the line most used by Volkswagen (VW) executives after the arrest of their fellow executive, Oliver Schmidt, this past week at the Miami airport. According to an article in the New York Times (NYT), entitled...more

Compliance Trends and Predictions for 2017

The past year was another great success for the compliance profession and related technologies. Compliance continues to grow as the “professionalization” of compliance continues to skyrocket. As my good friend Donna Boehme...more

Keep Your (Compliance) Eye on the Road

It is time to give a shout out to one of Houston’s hometown hero’s, the Houston Rockets. Until the Houston Dynamos came along, they were the only professional sports franchise to bring a championship to Houston. They brought...more

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

Compliance into the Weeds-Episode 23, Six Compliance Issues to Consider in 2017 [Video]

In this episode, Matt Kelly and I consider six compliance-related issues every compliance practitioner should watch in 2017. ...more

5 Trends in Whistleblower Hotlines and Protections to Be Aware of in 2017

Every year it’s safe to assume that our list of Top 10 trends will include the latest developments pertaining to helplines, whistleblower reporting and retaliation, and this year is no exception. We begin by examining some...more

For the CCO: Limit Your Self-Reliance

Many compliance professionals in the corporate world work long and hard to rise up to the senior management level in their organizations. It takes subject matter expertise, hard work and sometime propitious good fortune to...more

30 Days to a Better Compliance Program

Last summer I ran a two-week, combined blog and podcast series on the Ten Hallmarks of an Effective Compliance Program. The series was quite well received. As I fancy myself the Nuts and Bolts compliance guy and inspired an...more

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

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

Focus On Enabling Your People, Not Controlling Them, To Create an Effective Compliance Culture

When employees of all levels believe in and support policies and standards, that’s when you see real compliance. In-house perspective from NetApp GC, Matt Fawcett....more

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

E-Mail Communications: The Devil is on the Server

It is hard to imagine how prosecutors were able to bring cases before there was email communications. When I was a prosecutor, we looked for evidence in a lot of other sources, internal memos, calendars and other places where...more

Forget About a Risk Assessment – Conduct a Risk AND Compliance Program Assessment

A Chief Compliance Officer can get lost in terms, titles, risk management solutions, effective services, magic bullets, absolute requirements and ultimately confusion. Whether the strategy is called lines of defense or some...more

The Baker Hughes GeoMarket Ethics and Compliance Committee

Two of the most common compliance focused committees for public companies are those at the Board level and those which sit between the Chief Compliance Officer (“CCO”) and the Board, usually consisting of very senior...more

Shortchanging the Compliance Function

A company that does not back up its words with deeds is doomed to suffer compliance and cultural breakdowns. When a company commits to building a culture of trust and integrity, the company has to keep its word. This is not a...more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

2016 was an eventful year in the world of ethics and compliance. We lived and learned through the first year of the Yates Memo; we faced the momentous Brexit and dissected what it would mean for ethics and compliance; we...more

Code of Conduct Training – Now What?

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

To Sir, With Love – Compliance and the End of the Org Chart

In a recent On management column in the Financial Times (FT), entitled “Technology and millennials are out to kill the org chart”, Andrew Hill discusses how the org chart may soon be relegated to a relic of the past. From his...more

From the Fats Domino Sound to Execution in Compliance

Adam Bryant, in his Corner Office column, profiled Deirdre Quinn, the chief executive of Lafayette 148 New York, a women’s fashion company, in a piece entitled “If a Meeting Starts at 9, Be There at 8”. Quinn had some...more

France’s Major Anti-Corruption Reform: What’s Next for Companies and Their Top Management?

Changes to France's anti-bribery system require large companies and their top management to implement an anti-corruption compliance program. After a new examination of the bill by both Chambers of Parliament and the...more

CCOs Cannot Ignore C-Suite Risks

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

Godspeed to John Glenn and Failures at Deloitte

Last week, I paid tribute to Greg Lake. It turned out that the first full week of December was the final week for several important, if not seminal, figures. So this week I will pay homage to those who have left us, today I...more

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