Chief Compliance Officers

News & Analysis as of

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

2015 Trends: #9 Technology-enabled ethics and compliance is ready for takeoff

By every indication we are about to witness a dramatic leap in technology-enabled ethics and compliance. Tech Advancement in Key E&C Areas - Trends and our own client experiences are demonstrating that we are...more

The Patriots, the NFL and Compliance

You knew it was coming. No, not a Cialis-themed blog post, but close enough, ‘Deflategate’ and the compliance angle. In honor of this weekend’s Super Bowl it is certainly worth considering. You might think with all that is...more

Healthcare Compliance Programs: Stepping Up the Game

The Affordable Care Act was enacted in 2010 – can anyone remember back that far? The ACA required Medicare and Medicaid providers to have an ethics and compliance program....more

Franchising and Liability Under the FCPA

I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more

Catching Up on the False Claims Act

From a corporate risk perspective, if your company is in the financial industry, healthcare, or defense industry, your greatest legal and compliance risk has to be the False Claims Act....more

2014 Corruption Perceptions Index Highlights Need for Greater International Cooperation

Following the release of Transparency International’s 2014 Corruption Perceptions Index (CPI), the international watchdog group urges greater international cooperation to stem corruption and abuses of power that undermine...more

Good Bye to Mr. Cub, the Siege of Vienna and Doing More Compliance with Less

Let’s play two! That was perhaps the most famous maxim from Ernie Banks, who died this past weekend at the age of 83. As for a sobriquet, it does not get much better than being known as ‘Mr. Cub’ from any baseball fan from 9...more

Healthcare Fraud: Aggressive Enforcement Strategies

This week I am focusing on the persistent problem of healthcare fraud. For healthcare providers, the challenge of compliance and avoiding enforcement risks is particularly difficult. ...more

Time To Apply A Risk-Based Approach To Information Security Training

Digital warfare seems to be the name of the game these days. Terrorists attack our database infrastructures and wreck havoc by making personal information public. Look at the most recent attacks on Sony, Chick-Fil-A and...more

2015 Trends: #8 Top Whistleblowing Priorities for Compliance Professionals

Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more

Both Sides Now and Asking the Right Compliance Questions

One of my favorite singers has always been Judy Collins. Like most of us, I was introduced to her through her interpretation of Joni Mitchell’s song Both Sides Now which she released in 1967. Joni Mitchell did not record her...more

Five 2015 Corporate Compliance / Litigation Issues Manufacturers Need To Keep An Eye On

It is our annual tradition at the beginning of each year to report on significant issues that face manufacturers/distributors in the year ahead.  Two weeks ago, Matt reported on significant issues in the labor/employment...more

FCPA Compliance and Ethics Report-Episode 124, The Oscars and Compliance, Part I with Jay Rosen [Video]

In this episode I begin a five-part series on the Oscars and Compliance with recovering Hollywood screenwriter Jay Rosen. In this Part I, we review the process by which films are nominated for the Oscars and the campaigns...more

Sunlight on Corruption: An Important Strategy in the Global Anti-Corruption Movement

Everyone is against corruption. Everyone knows that corruption can stifle economic development and increase economic disparity and poverty. When government officials take money for their own benefit, they are robbing the...more

Doubling The Impact of Your Ethics and Compliance Program With A Liaison Network

Last week we had the pleasure of listening to Jeff Piposar, Director and Executive Advisor for CEB Compliance & Ethics, share how to multiply limited resources in our webinar, “Building A Scalable Compliance Infrastructure:...more

2015 Trends: #7 Crime and Punishment

On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more

ESMA Recommends to the European Commission That All MiFID Firms Have a Full-Time Compliance Function

The European Securities and Markets Authority’s (ESMA’s) final advice to the European Commission, which may (if the European Commission concurs) be transposed into new rules under the revised and re-cast Markets in Financial...more

Just Say No, the Power of No and Compliance

What is the first thing that you think of about Former First Lady Nancy Reagan? Right up there for me is three things actually Just Say No, which was her campaign against not only drug abuse but also premarital sex in the...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Language Solutions as Preventative Tool in Anti-Corruption Compliance

Ed. Note-I partnered with Merrill-Brink to write a White Paper on the use of local languages as a preventative tool in FCPA, UK Bribery Act and anti-corruption compliance. Today’s blog post is an excerpt from the full article...more

Ethics in Pharmaceutical Sales: Strengthening Corporate Culture and Preventing False Claims Act Violations

“I didn’t set out to commit a crime. I certainly didn’t set out to hurt anyone… I was kind of a hero, because I helped the company make its numbers every quarter. And I thought I was doing a good thing. I thought I was...more

Revisiting The Raven and Visiting Foreign Subsidiaries

Today we celebrate the birth of one of America’s most iconic authors, Edgar Allen Poe, who was born on this day in Boston, Massachusetts. Anyone who reads or watches a mystery show on television owes a debt to Poe for...more

Top 5 Ethics and Compliance Trends for 2015

Ethics and compliance had a terrific year in 2014. The profession is growing in response to increased demand from businesses that are “slowly” embracing the importance of ethics and compliance....more

FinCEN Fines Former CCO For Maintaining Ineffective AML Program

Recently, FinCEN announced a $1 million civil money penalty against the former Chief Compliance Officer (CCO) of a large financial services company for allegedly violating the Bank Secrecy Act (BSA) and its implementing...more

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