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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 -

Ethics and Compliance Controls – Different Means to the Same Objective

by Michael Volkov on

People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

No More Excuses: CCOs Have to Embrace Technology

by Michael Volkov on

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

Criminal justice: How best to stop economic crime

by WilmerHale on

Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more

Farewell to a Repo Man and Using Laconic Persuasion as a CCO

by Thomas Fox on

The life of a Repo Man is always intense… That was one of the greatest lines from one of the greatest movies from one of the greatest laconic actors of all time. Of course it was Harry Dean Stanton who died over the...more

4 Signs of a Poor Relationship Between a CCO and the Board

by Michael Volkov on

Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

The COSO ERM Framework

by Thomas Fox on

The COSO Enterprise Risk Management (ERM) Framework was released last week. It provides an excellent structure for compliance practitioners and businesses to think through the entire lifecycle of risk management....more

CCOs and the C-Suite

by Michael Volkov on

Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance....more

Slippery Slopes: “Broken Windows” and Employee Misconduct

by Michael Volkov on

Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to...more

Your Company Brand and Ethical Behavior

by Thomas Fox on

Last week, I was interviewed by David Banks, the Senior Content Marketing Manager at NAVEX Global, for the firm’s blog. One of the questions he posed to me struck me and it was “When it comes to contributing to a greater...more

AML/CTF - A decade’s experience

by Dentons on

As the AML/CTF regime approaches its 10th birthday, what are the key issues for the finance industry? From 12 December 2007 reporting entities are required to have in place an AML/CTF program documenting how they...more

The Emperor Has No [Compliance Program]

by Michael Volkov on

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more

Using Data to Improve Your Compliance Bench Strength

by Thomas Fox on

In the September edition of One Month to a More Effective Compliance Program, I am focusing on innovation in compliance. There are many ways to innovate through the use of data. One of the interesting ways is through hiring...more

Compliance Leadership Tips from the Surgeon General-the Art of Persuasion

by Thomas Fox on

For myself, September 11th is the most solemn day in the history of our country that I have lived through. Others of my parents’ generation point to December 7th with the same reverence I feel as the day America was attacked....more

Will Your Assets Be Stranded? The Risk Management Process in ESG and Compliance

by Thomas Fox on

State Street Global Advisors (SSGA) is a company which engages in US and broader international institutional investing, largely on behalf of its clients. Some of the areas it focuses on include environmental, sustainability...more

Day 4 of One Month of Innovation in Compliance-Welcome to ComTech

by Thomas Fox on

What will be the role of Artificial Intelligence (AI) in compliance going forward? LawTech had disrupted the legal profession and how it is reshaping many areas of private practice. I found the article had multiple...more

Operationalize Compliance; Operationalize Culture

by Thomas Fox on

More and more the issue of corporate culture is coming to the fore in the area of compliance. It works for all levels of a company, literally from the Boardroom to the shop floor. The Department of Justice (DOJ) and...more

Compliance Missed Opportunities: CCOs and HR

by Michael Volkov on

A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.”...more

How Weather Can Bring Analytical Clarity to Compliance

by Thomas Fox on

Sometimes I pick a topic for a week’s theme of blog posts, as I did last week with the topic of soft skills needed to navigate a successful remediation. Then there are times where it appears the theme picks me or at least...more

Focusing Antitrust Compliance Programs on the Real Criminal Risks (Part II of II)

by Michael Volkov on

As chief compliance officers realize the importance of criminal antitrust compliance, it is important to identify the real risk factors. All too often we get lost in the mumbo-jumbo (a technical term, I know) of compliance,...more

Soft Skills in Remediation: Part V – Post Resolution

by Thomas Fox on

I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more

Day 19 of One Month to More Effective Continuous Improvement-Use of Social Media for Continuous Improvement

by Thomas Fox on

Compliance does not exist in a time-warp vacuum, with programs living in 1977 when the first major anti-corruption legislation, the Foreign Corrupt Practices Act was passed. The law has advanced since that time, as has...more

DOJ's FCPA Pilot Program is Alive and Well: Two Superior Results in Declinations for Linde Gas and CDM Smith

by Thomas Fox on

Companies have a clear road map to resolve substantive FCPA violations with no criminal penalty. ...more

Chief Compliance Officers Have to Address Criminal Antitrust Risks (Part I of II)

by Michael Volkov on

We often read articles and blog postings about anti-corruption, anti-money laundering, export controls and sanctions compliance issues. The focus on these topics is justified. However, there is one glaring omission –...more

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