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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 -

CCOs and Resources: Put Your Money Where Your Mouth Is!

by Michael Volkov on

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more

The PCAOB, Audits, and Compliance - Considerations for the Chief Compliance Officer

by Thomas Fox on

I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might...more

Are Risk Assessments Just a Report on the Obvious?

by Michael Volkov on

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more

5 Telltale Signs of a Weak Corporate Culture

by Michael Volkov on

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the...more

Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress

by Michael Volkov on

Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more

The Uber Board Report – Part I

by Thomas Fox on

On Tuesday, the law firm of Covington & Burling LLP (Covington), released its long-awaited report (Report) to the Special Committee of the Board of Directors of Uber Technologies, Inc. (Uber). It is truly one of the most...more

Day 9 of One Month to Better Reporting and Investigations-The Investigation Team

by Thomas Fox on

Beginning with the Department of Justice’s (DOJ’s) Yates Memo, its Foreign Corrupt Practices Act (FCPA) Pilot Program and then the release of the Evaluation of Corporate Compliance Programs (Evaluation), I believe the DOJ has...more

Farewell to Batman and Bringing Passion to Compliance

by Thomas Fox on

Adam West died this weekend. He was the TV Batman I knew growing up. They say the actor who first introduced you to a character will always be your favorite and while I am not sure if that holds true or not with West’s...more

Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation

by Thomas Fox on

Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more

Preparing for an Investigation

by Thomas Fox on

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

Trial and Error in Compliance

by Thomas Fox on

One of the highest values in the corporate world is consistency. While being stubborn can be an asset in the corporate world, it can be risky but when it takes being consistent too far. ...more

“The Future is Now” — Compliance and Technology

by Michael Volkov on

This posting is not a “pie in the sky” outline of compliance in the future, when technology works seamlessly with compliance functions. My focus today is on what is happening now in the compliance world when it comes to...more

2016 - A Year for the FCPA Record Books & What It Means for Compliance Practitioners

by Thomas Fox on

We have never seen and may well never see again a year of Foreign Corrupt Practices Act corporate enforcements as we did in 2016. ...more

A CCO’s Challenge: How to Convince a CEO to Embrace Compliance

by Michael Volkov on

A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he...more

The Stoic's Guide to Compliance

by Thomas Fox on

One thing about successful Chief Compliance Officers (CCOs) and other compliance practitioners is they can take in severe news, keep calm and carry on. In a keynote speech to the SCCE Compliance and Ethics Institute, Jenny...more

Ensuring Compliance with Controls

by Michael Volkov on

Let’s start with some basics – a public company is required to implement a set of internal controls. A compliance program is a critical part of a company’s internal controls. A company’s compliance program is only as...more

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

by Thomas Fox on

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

The Spirit of Compliance

by Thomas Fox on

One of my weekend pleasures is reading Peggy Noonan’s column in the Wall Street Journal (WSJ). Each week is filled with wit and insight and some of the finest writing around. This past week, in an article entitled “Why...more

Sgt. Pepper’s at 50 – Leadership Lessons from the Faux Band

by Thomas Fox on

The 50th anniversary of the release of Sgt. Pepper’s Lonely Hearts Club Band is reason alone for celebration. But you can use the album, its themes and images to enhance your compliance regime. As it is also my favorite...more

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

The Future of Compliance – Today and Tomorrow

by NAVEX Global on

Compliance Week 2017 is in the books now. The conference opened with futurist, Dr. Brian David Johnson from the Threatcasting Lab at Arizona State University as its first keynote speaker. The mission of the lab and of Dr....more

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

Day 20 - Compliance Leadership from the Bottom

by Thomas Fox on

The key concept from the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Program (Evaluation) is operationalization. For instance, under the query Shared Commitment is the following question - “How is...more

The Compliance Profession Needs to Adopt Professional Standards

by Michael Volkov on

Those who regularly read my blog have heard me often cite the need for the compliance profession to adopt professional standards. With the rise of the profession, and the expectations placed on the shoulders of compliance...more

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