Chief Compliance Officers

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Second Circuit Rejects Extraterritorial Application of Dodd-Frank’s Whistleblower Anti-Retaliation Provision

On August 14, the United States Court of Appeals for the Second Circuit became the first U.S. appellate court to weigh in on the extraterritorial application of the whistleblower provisions of the Dodd-Frank Wall Street...more

Second Circuit Holds Dodd-Frank Whistleblower Provision Does Not Apply Extraterritorially

Last week, in Liu v. Siemens, AG, the Second Circuit held that the Dodd-Frank Act’s whistleblower retaliation provision (15 U.S.C. 78u-6(h)(1)) does not apply extraterritorially, in the first Second Circuit decision to...more

Happy Birthday Dodd-Frank: The Whistleblower Program Milestones and How They’ve Impacted Business Ethics Training

Did you have some cake? Break out the balloons? While it’s hard to believe, it is true. Our little Dodd-Frank, signed into law by President Obama in 2010, is already four years old and about ready for pre-school. Although we...more

The Absence of a CECO and the GM Fiasco

This is a posting that I have wanted to write since the GM scandal occurred. I have to start with a rhetorical question – Would the GM debacle have occurred if GM had an independent and empowered Chief Ethics and Compliance...more

Top Ten Tips for the Workplace

Every now and then, it’s worth it for even the most seasoned HR professional to receive a reminder about best practices in the workplace. Ensuring compliance with our Top Ten Tips list below, will help to keep your workplace...more

Lauren Bacall Whistling or How to Structure Customer Due Diligence

Yesterday I wrote about the Foreign Corrupt Practices Act (FCPA) investigation into certain transactions in Venezuela by Derwick Associates (Derwick) and a US company ProEnergy Services (ProEnergy). ProEnergy supplied...more

What’s Scarier than a Compliance Officer Turned Whistleblower? A Whole Association of Them

In U.S. ex rel. Corporate Compliance Assocs. v. N.Y. Society for the Relief of the Ruptured & Crippled the court ruled that the whistleblower failed to meet the False Claims Act’s requirement that allegations be described...more

The Corporate Representative’s Deposition Bill Of Rights (And Wrongs)

Your company’s general counsel just “voluntold” you that you’re going to be deposed as the company’s representative in a court case that you’ve never heard of. What in the world is she talking about, and what will you have to...more

Na-Nu Na-Nu – Final Report to Ork From Mork – Information from FCPA Inquiries

A Venezuelan company, Derwick Associates (Derwick), are under investigation by the Department of Justice (DOJ) and Manhattan District Attorney’s office. Derwick was reported to have been “awarded hundreds of millions of...more

Five Essential Improvements to Corporate Governance

Continuing with my list theme for the week, it is important to remind everyone that a culture of compliance begins with the board of directors, filters to the CEO who commits to promoting ethics and compliance in the company,...more

Conducting Interviews in an Internal Investigation 2 13 14, 9 03 AM [Video]

The ability to conduct an effective internal investigation is critical for every organization. The interviews of witnesses are the most important aspect of any internal investigation. In response to interest in holding...more

Thinking Through Risk Rankings of Third Parties

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more

Four Ways to Improve Antitrust Compliance Programs

In the era of global antitrust cartel enforcement, antitrust practitioners often scratch their collective heads and ask why is antitrust compliance so ignored by government enforcement agencies....more

How Vendors Can Add Value to Your Resource-Constrained Ethics And Compliance Training Program

Too many times we see the providers of ethics and compliance services disappear after they have sold an ethics and compliance training program or ethics and compliance policy management system. ...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

Five Ways for CCOs to Enhance Their Professional Qualifications and Status

Chief Compliance Officers are the rising professional stars in the corporate employment landscape (along with IT professionals who have practical perspectives). The profession is at an important test – where will the...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Five Most Common Weaknesses in Anti-Corruption Compliance Programs

In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick...more

The Empire State Strikes Back: New York Proposes Rules for Virtual Currency

The New York State Department of Financial Services (the “Department”) recently published its proposed rules and regulations (the “Proposed Rules”) for vendors conducting business involving virtual currency. The Proposed...more

Consumer Complaint Database and Public Narratives

For some time we have known about the Bureau’s “Consumer Complaint Database” (“Database”). The Bureau’s new proposal would expand the “public-facing database” to include “unstructured consumer complaint narrative data”...more

Where to Now St. Peter? – Due Diligence Going Forward in China

Whatever you might think of where his career went, Elton John had some great early stuff. I still rank Tumbleweed Connection right up there as one of my favorite albums of all-time. And while it was packed with some great...more

Who Should Take Conflict of Interest Training?

The other day I wrote about antitrust training and I opened with describing how it is one of the less popular training topics, or at least I perceive it to be. I never thought I’d get remotely interested in something like...more

SEC Brings First Whistleblower Anti-Retaliation Enforcement Action

On June 16, 2014, the U.S. Securities and Exchange Commission (SEC) resolved its first whistleblower retaliation enforcement action. The SEC’s order against Paradigm Capital Management, Inc. is the first-ever enforcement...more

10 Tips for Preventing Third-Party Harassment and Discrimination

Workplace harassment is a serious issue, whether it involves unwanted sexual advances or derogatory remarks about a person's race or skin color. Employment laws hold employers responsible for ensuring that the workplace is...more

Nixon Announces Resignation; GSK Just Resigns

Next week, Shanghai’s No. 1 Intermediate People’s Court is scheduled to open a trial against Peter William Humphrey, a 58-year-old British national, and his wife, Yu Yingzeng, a 61-year-old American, on charges of illegally...more

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