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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Internal Controls Outside the US – Part IV

This post will conclude a short series I have presented on the issue of internal controls outside the US. I want to conclude by raising some ways in which a compliance professional can work to implement internal controls in a...more

The Mummy and Internal Controls in Locations Outside the US – Part III

Today we celebrate Hammer Film’s version of The Mummy. This was the first film that the Hammer studios made under a license agreement with Universal Pictures, the holder of the copyright of its classic monsters from the 1930s...more

Implementing compliance programme at the emerging markets of the former Soviet Union

Ed. Note-today we have a guest post from Timur Khasanov-Batirov, Chief Compliance Officer at DTEK and Co-Chairman at Compliance Club of the American Chamber of Commerce in Ukraine. It will be a challenge. I mean to...more

Anti-Bribery Training from Coca-Cola: What I Learned About Bribery, Corruption and Responsibly Entering Underdeveloped Markets

A few weeks ago, I had the pleasure of attending the 22nd Annual Ethics and Compliance Conference, hosted by the ECOA. I’m always intrigued by how the topics of a conference tie together; for example, one of the speakers on...more

Effective Risk Management Needs More Ownership by Third Parties

Third-party arrangements continue to proliferate despite increased regulatory scrutiny meant to boost compliance with a variety of complex laws and regulations, making third-party risk management more important than ever....more

Higher Education Compliance and the Scourge of Campus Sexual Assaults

Chief Compliance Officers who lament the challenges of their jobs should be thankful they are not in charge of compliance for higher education institutions. The culture of compliance has extended into many high-risk areas but...more

Steve Bartman and Internal Controls Outside the US, Part II

Today, we note that 11 years ago, Steve Bartman entered the Chicago Cubs Hall of Infamy. For every baseball fan, if there was ever a but for the grace of God, go thee moment the sad saga of Bartman is it. The Chicago Cubs,...more

Workplace Drug Policies and Your Corporate Culture: Four Tough Questions To Ask and Answer

For employers, enforcing workplace drug policies in states where medical marijuana use is legal could boil down to workplace values and culture. And it’s an issue companies will be facing more and more....more

SEC Division of Corporation Finance Issues New C&DI Related to Rule 147 and Website/Social Media Use

On October 2, the Securities and Exchange Commission’s Division of Corporation Finance issued a new Compliance and Disclosure Interpretation (C&DI) regarding whether an issuer of securities may use its own website or social...more

Reflecting on the E.U. Ethics & Compliance Landscape: One Year After Opening Our U.K. Office

The growing shift in the E.U. away from piecemeal ethics and compliance programme components and towards a more comprehensive approach is an important and exciting evolution to witness....more

Ringo, Sir Paul and an Effective Compliance Program

Sometimes the universe converges in ways that are beyond my simple comprehension. This past weekend was one of them. It began a few months ago when I saw an advertisement from StubHub that showed Ringo Starr playing in...more

The Horror of Dracula and Internal Controls in International Locations, Part I

This Friday we celebrate the second in the Hammer Films horror series, which was actually its first offering, based on Count Dracula, entitled “Horror of Dracula”. It starred the famous Hammer Films horror movie two-some of...more

Tribute to Jim McGrath

Ed. Note-Jim McGrath died this week. He was a good friend and a trusted colleague. My thoughts are with his wife, sister and her family and his parents and the rest of us who were privileged to know Jim. ...more

Don’t Bore your Board: Seven Tips for Delivering an Engaging Ethics & Compliance Board Training Experience

If you are like most compliance officers, the thought of training your board on compliance risks may make your heart start beating just a little faster—and the task can quickly start to seem insurmountable. After all, it’s...more

Compliance Challenges: When the Almighty Dollar Rules

Chief Compliance Officers have to recognize one immutable fact – if a company does not make money, compliance does not matter. I know this is hard to fathom but a company’s purpose is to make money. The issue boils down to an...more

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more

5 Halloween Office Celebration Risks To Address In Your Code Of Ethics Training

Halloween is one of my favorite holidays. For one day out of the 365/366 days of the year, everyone has the opportunity to be anyone or anything they want to be. It’s a blast. Over the last few years, I’ve been “your mom”, a...more

The Positive Effects of DPAs and NPAs in FCPA Enforcement

One of the oft-made criticisms regarding the Department of Justice (DOJ) around its enforcement of the Foreign Corrupt Practices Act (FCPA) is its the use of Deferred Prosecution Agreements (DPAs) and Non-Prosecution...more

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Part Five

The Congressional debates - The revelations from the Watergate hearings and the Commission’s investigations and enforcement actions sparked two years of Congressional hearings. Those revelations also spawned a...more

Ten Requirements for an Effective Due Diligence System

The purpose of a due diligence system is not to identify and prevent hiring of a third-party who will commit bribery. To the contrary, no one can predict with accuracy who will commit bribery, unless they truly have...more

Chief Compliance Officer as Chief Persuasion Officer

The roles of a Chief Compliance Officer (CCO) can be many and varied but one role of any successful CCO is that of Chief Persuasion Officer (CPO). I say this because it is often the case that the most a CCO has in his or her...more

FinCEN’s Culture of Compliance Advisory: A Strong Message

Cynics can easily dismiss FinCEN’s August 11, 2014 Advisory on Promoting a Culture of Compliance (Here). In fact, FinCEN’s Advisory contains several important messages, which need to be emphasized....more

8 Tips for Verifying the Effectiveness of Corporate Anti-Corruption Programs

In the past 20 years, considerable progress has been made in developing corporate anti-corruption programs, as companies recognize the damaging effects of bribery and corruption on business, reputations and the global...more

The Mitford Sisters and the Compliance Audit

Deborah Cavendish died last week. She was the last surviving member of an extraordinary group of women known as the ‘Mitford Sisters’. They were six daughters of David Freeman-Mitford, the 2nd Baron Redesdale and the former...more

An ethics and compliance program in seven steps

Establishing compliant and ethical behaviour among the masses, and regulating against non-compliance is a big step in the fight against fraud and abuse. All organizations have their own unique plan in the running of their...more

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