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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 -

Operationalizing Compliance: Part I – It All Starts with Pizza

by Thomas Fox on

With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper...more

The Astros, Regression to the Mean and Compliance

by Thomas Fox on

Being a Houston baseball fan has been largely pain, misery and suffering. While we have not gone 80+ years or even a century without winning a World Series it is not for lack of ineptitude. It is because the Houston Major...more

Compliance Program Oversight - The Board’s Overlooked Role

It’s long been axiomatic that an effective compliance program cannot exist without a strong ethics and compliance culture, which in turn requires the proper “tone from the top.” Yet, when most companies think “top,” they...more

The Renovated Globe Theater and Operationalized Compliance

by Thomas Fox on

There is much that a Chief Compliance Officer (CCO) or compliance practitioner can learn from Shakespeare. I have often used his plays as introductions to blog posts or as examples to inform a compliance program. Today, I...more

Effective Compliance and the Importance of Accounts Payable Function

by Michael Volkov on

As the compliance function has matured, Chief Compliance Officers have built important relationships with related functions that are critical to the compliance function. Over the last few years, we have seen the Justice...more

From Dr. No to an Agile Compliance Program

by Thomas Fox on

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

The State of Mind of a White Collar Criminal

by Michael Volkov on

As a chief compliance officer, it is important to consider the mindset of a criminal. Not to complete tasks and accomplish your objectives. Instead, it is important to understand the criminal mind, what makes them tick and...more

Setting Your Compliance Program by the North Star

by Thomas Fox on

Today I celebrate a potpourri of history to lead into some leadership lesson for a Chief Compliance Officer (CCO) or aspiring CCO. According to This Day In History, today marks the second formation of the Committees of...more

MoneyGram CCO Pays Civil Penalty

by Michael Volkov on

Like any other profession, the compliance profession is not immune to bad apples. Lawyers know the law but have been criminally prosecuted for breaking the law. The same goes for compliance professionals....more

Don’t Outsmart Yourself: AI and Compliance

by NAVEX Global on

I’m a big fan of artificial intelligence. The older I get, the more I appreciate that real intelligence needs all the help it can get. Corporate ethics and compliance officers, however, need to pause before betting big on AI...more

The Compliance Profession and the Demand for “Results”

by Michael Volkov on

Compliance professionals are riding high. They are the darlings of the corporate governance world, commanding higher salaries, C-Suite positions with access to senior leadership and the board, and an empowered position within...more

The Trump Administration: The Business Impact

by Thomas Fox on

If we do not speak up, there may not be an opportunity later. ...more

Four Essential Leadership Behaviors

by Thomas Fox on

The role of any leader should be engagement, engagement and then more engagement. By understanding the needs of your key stakeholders and incorporating that into your solution or initiative you will have your team on board...more

10 Questions to Operationalizing Compliance

by Thomas Fox on

A Harvard Business Review (HBR) article, entitled “Does Management Really Work?” by Nicholas Bloom, Raffaella Sadun and John Van Reenen, provided some succinct advice about what a business can do to improve its management...more

Moving into New Space – Communicating the Operationalization of Compliance

by Thomas Fox on

While many are no doubt celebrating Cinco de Mayo today, it is also the 66th anniversary of the first foray into space for the US, albeit in a sub-orbital way. It was on this date in 1961, that Navy Commander Alan Shepard was...more

Farewell to Racehorse and Welcome to Project Success

by Thomas Fox on

Every trial lawyer in Texas has heard of him, a legendary trial lawyer with a legendary name, Richard ‘Racehorse’ Haynes; who died over the weekend at the age of 90. He took up the mantel of great Houston criminal defense...more

The Revolution in Compliance Training – It is Not Just About Your ABCs

by Michael Volkov on

A CCO never feels like he or she has caught up on compliance program requirements. As soon as one new best practice is identified, a CCO blinks for a moment and then there is a new best practice for them to consider....more

Knowing Your Employees and Incident Management Systems

by Michael Volkov on

Chief compliance officers know the importance of trust, not just as a foundation of a global company’s compliance program, but in the context of knowing what company employees are doing out in the field. CCOs will always say...more

Attorney General Sessions reemphasizes DOJ commitment to FCPA enforcement, individual accountability: 4 takeaways for business

by DLA Piper on

As the Trump Administration wraps up its first 100 days, practitioners have a bit more clarity regarding how the new Administration will assess corporate compliance programs, cooperation and white collar cases. Over the past...more

Compliance is Not “Rocket Science”

by Michael Volkov on

In the compliance arena, like in many others in life, we value simplicity. I have repeatedly stressed the importance of compliance initiatives that are relatively simple. Too often, lawyers and compliance professionals...more

Data Analysis In a Compliance Best Practices Program

by Thomas Fox on

An in-depth look at the use of data analysis in a best practices compliance program under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act or other anti-corruption compliance regime....more

Suggested Questions for the Compliance Officer

by Ruder Ware on

In a previous blog post, I promised to release a list of questions a Board of Directors (Board) might ask its compliance officer. This post is intended to fulfill that promise. My intent is to help Board members exercise...more

Writing Tips Inform Your Compliance Program

by Thomas Fox on

Today I consider some tips from the world of fiction composition for your compliance program. These lessons are applicable for both the design, enhancement and implementation of your compliance regime. Moreover, by...more

Exercising Board Oversight of the Compliance Function

by Ruder Ware on

The Board of Directors (Board) of an organization has oversight responsibilities over the compliance program. Board members are often unsure of the nature and scope of their responsibilities over compliance. The roll of many...more

Measuring the Effectiveness of a Compliance Program

by Thomas Fox on

How does one measure effectiveness? In Wichita, Kansas, in 1876, when it came to town a Deputy Sheriff, the final measure was the elected government. On this day in that year, the town’s Commissioners voted not to extend the...more

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