Corporate Culture

News & Analysis as of

Compliance Meaningfulness: Hard to Achieve, Easy to Destroy

In an article titled, What Makes Work Meaningful- Or Meaningless by Catherine Bailey and Adrian Madden (MIT Sloan Management Review, Summer 2016), the authors focus upon what makes our work meaningful, with research...more

Compliance Training – Part III: Effectiveness and Evaluation

This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I...more

Are You Focusing Too Much On Your Diversity Program?

Diversity is a good thing. Actually it’s a great thing. It’s good for business in many ways. But the focus on diversity in the legal industry has become, for the most part, an exercise too tied to metrics and too formalized...more

A Rush to Compliance: Patience is a Virtue

Compliance officers are, by definition, goal driven. They are high achievers and expect to succeed. So what. You may say – we all know that. Compliance officers are not the most patient group of people. They want to see...more

How to Simplify Your Code of Conduct Attestation Language

What does your code of conduct acknowledgement process look like? If your annual attestation language is long, confusing or overly complicated, you run the risk of alienating your employees—and missing an opportunity to...more

What’s Wrong with Perfect? In Today’s Changing Environment, A Lot

Perfectionism is a tendency with which many of us have an intimate familiarity. In our personal lives, we acknowledge that demanding perfection from those around us, such as our spouses or children, is detrimental and can...more

Practical Tips for Effective Corporate Compliance

SEC personnel frequently speak publicly on a variety of topics. Some speeches are less than memorable, while others so perfectly capture the essence of a subject and provide such practical insight that it would be a shame for...more

Experian sponsors Ponemon study on data breach

Experian Data Breach Resolution sponsored a recently released Ponemon Study entitled “Managing Insider Risk through Training & Culture.” The report is quite timely in light of all of the recent successful W-2 phishing...more

Do Former Prosecutors Make Good CCOs?

A number of companies have adopted the requirement that a new Chief Compliance Office come from the ranks of former federal prosecutors. I am not sure exactly why companies have adopted this requirement. Perhaps company...more

The Non-Pairing of Two Great Sports Announcers: Lessons for the CCO

I grew up listening to the Houston Astros on the radio. It was not because my family was totally retro. We were not that cool at all, it was simply at the time I grew up, in a time, the 1960s and a place, Bryan, Texas, where...more

Advertising won’t fix this

Over the years, I worked with many organizations starting back with student political organizations and the school paper at Stony Brook. This includes actual businesses, civic and religious organizations. Many of these...more

“It’s Not a Culture War” – Yet?

On May 23, 2016, at FINRA’s annual conference in Washington, D.C., Richard Ketchum, FINRA’s chairman and CEO, delivered a speech that shed a little light on FINRA’s recent sweep letter relating to firm culture....more

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Bridging the Week - May 2016 #4

Two Related Broker-Dealers To Pay US $17 Million for Widespread AML Compliance Failures; Former AML Compliance Officer Also Sanctioned: Raymond James & Associates, Inc. (RJA), Raymond James Financial Services, Inc....more

Citadel, a $24-Billion Hedge Fund, Seeks Whistleblower Status

Just a few months after announcing the first-ever award to an outside whistleblower, federal authorities may be on the verge of expanding the reach of whistleblower incentives even further. Last week, Citadel, the...more

Top Three Findings from our 2016 EMEA & APAC Hotline Benchmark Report

Benchmarking your organisation’s data against your peers across EMEA & APAC provides critical insights into the health of your ethics and compliance programmes. Our new report gives the most comprehensive picture of...more

Bridging the Week - May 2016 #3

Controller of FCM Named in CFTC Complaint, Along with Firm, for Failure to Timely Notify Commission of Segregation Breach: Cunningham Commodities, LLC, a futures commission merchant registered with the Commodity Futures...more

UK Financial Regulatory Developments - May 2016 #7

MAS updates business plan - MAS has published an updated business plan for 2016-2017. The changes reflect criticism that MAS was spending too much time and money building its own brand and developing its own website. It...more

Teaching the Board How to Oversee and Monitor the Compliance Function

I have never let my schooling interfere with my education – Mark Twain (unverified). Everything has its limit–iron ore cannot be educated into gold. – Mark Twain (verified) Board members believe they know what they...more

Trust and Integrity: The Value of a Company’s Reputation

Warren Buffet, the Oracle of Omaha, understands the importance of corporate culture and adhering to a code of ethics. He has been quoted: Lose money and I will forgive you. Lose even a shred of reputation and I will be...more

Selling a Company: Important Considerations as Discussed by the Experts

As tech founders and executives contemplate the possibility of exiting their companies, there are multiple factors they must consider. On May 3rd at FoleyTECH Chicago 2016, four seasoned entrepreneurs came together to discuss...more

Mother Maybelle and Effecting Change in an Organization

Today we celebrate great American music and honor one of its founders, Mother Maybelle Carter who was born on this day in 1909. Now known more as the mother of June Carter Cash, the wife of Johnny Cash, Mother Maybelle was a...more

Fixing a Sour Corporate Culture: Valeant Pharmaceuticals Faces an Uphill Challenge

Like the Greek mythology character Sisyphus, Valeant Pharmaceutical is attempting to atone for its sins and turn its corporate culture around. I am not usually a cynic but when I see these transparent attempts to reverse a...more

Campaigning for Self-Reporting and Calculation of Incentives (Part I of II)

Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential...more

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