Chief Compliance Officers

Tell A Story To Drive Compliance

by Thomas Fox on 5/17/2013

Sometimes a story will help you understand just what you did not understand. Did you know that the Federal Bureau of Investigation (FBI) launched a formal investigation in 1964 into the supposedly pornographic lyrics of the...more

Demonstrating The Effectiveness Of Your Compliance Program

by Michael Volkov on 5/16/2013

Hopefully, you and your company will never have to prove to a court or argue to the Justice Department that your anti-corruption compliance program is “effective.” ...more

Scam Artists From Texas And Compliance Risk Management

by Thomas Fox on 5/15/2013

Billie Sol Estes died yesterday and when it comes to scam artists from the great state of Texas, before there was Allen Stanford and his magical Certificates of Deposits located in his private bank in Antigua, there was...more

The Compliance Stepchild: Antitrust

by Michael Volkov on 5/13/2013

Let’s try and put this all in perspective. Last fiscal year, the Antitrust Division collected over $1 billion in criminal fines and sent a number of senior executives to prison. ...more

Turning CCOs Into Business Partners

by Michael Volkov on 5/10/2013

Chief Compliance Officers are basically optimists. In the face of a mountain of worst case scenarios (typically referred to as “risks”), CCOs keep smiling and work incredibly hard. ...more

Leveraging The Board And CEO Relationship To Improve Compliance

by Michael Volkov on 5/9/2013

In the age of superstar CEOs who command media attention and excessive compensation packages, a company’s performance can often boil down to the relationship between the Board and the CEO....more

Improving Your Anti-Corruption Training Program

by Michael Volkov on 5/8/2013

Chief Compliance Officers are usually very proud of their anti-corruption training programs. Most companies rely on a combination of live and on-line training programs to communicate the message of compliance....more

The Three Amigos/Amigas: Compliance, Audit And Legal

by Michael Volkov on 5/7/2013

Every compliance program depends on collaboration. No one actor at a company determines the success or failure of a corporate compliance program....more

SEC Sanctions Fund Trustees for Inadequate Disclosures and Failure to Follow Compliance Policies

by Jay G. Baris, Kelley A. Howes | Morrison & Foerster LLP on 5/3/2013

The Securities and Exchange Commission today charged the trustees of two “turnkey” mutual fund trusts with causing untrue or misleading disclosures about their review of the funds’ advisory contracts. The Commission also...more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

by Thomas Fox on 4/25/2013

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

The Hatfields And The McCoys: CCOs And GCs?

by Michael Volkov on 4/25/2013

Every company has its share of internal politics, rivalries and tensions. No organization is free from internal strife. For a company to be successful, you need talented, ambitious and intelligent people....more

The Danger Of FCPA “Proactive” Investigations

by Michael Volkov on 4/22/2013

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

Got 20 Minutes? Spicing Up Compliance Training

by Thomas Fox on 4/17/2013

How can you create or revise your compliance program? One of the first steps you should take is to devise an action plan. A recent article in the March edition of the Compliance Week magazine, entitled “Putting Together an...more

The Importance Of A Board Compliance Committee

by Michael Volkov on 4/16/2013

It is not every day that I can report on a new governance innovation which is being rapidly embraced and implemented by companies. It may be one of the most significant corporate governance developments in the last five...more

SEC Highlights Compliance and Ethics for Broker-Dealers

by David Smyth | Brooks Pierce on 4/11/2013

On Tuesday the SEC held a National Compliance Outreach Program for Broker-Dealers at an open meeting at its D.C. headquarters. The first panel – titled The Role of Compliance and Ethics – was nominally targeted to...more

An Independent CCO Is A Compliance Program Requirement

by Michael Volkov on 4/9/2013

I thought the debate was over on this issue: The train has clearly left the station for the “best practice” of separating the legal and compliance functions—empowering a separate chief compliance officer with direct reporting...more

Why Eat Your Words When You Can Eat a Peach?

by Thomas Fox on 4/9/2013

Taken to the woodshed or when should a company have to eat its own words? Remember when President Reagan’s Director of the Office of Management and Budget, David Stockman, was ‘taken to the woodshed’ by White House Chief of...more

Empowering The Chief Compliance Officer

by Michael Volkov on 4/5/2013

Sometimes the legal profession reminds me of the medieval guild system – a profession which is motivated more by self-preservation than change. You can always count on lawyers who cling to an outmoded perspective to try to...more

Three Compliance Interviews on April 3

by Thomas Fox on 4/4/2013

I attended the Dow Jones Global Compliance Symposium over the past couple of days. It was a great conference and kudos to the entire Dow Jones team for putting on a truly memorable event. Day 2 had some interesting speakers...more

CFTC No-Action Relief for Compliance Reporting

by Orrick - Structured Finance Group on 4/4/2013

On March 28, the CFTC issued a no-action letter providing limited relief, in certain circumstances, from the requirement that chief compliance officers of futures commission merchants prepare and submit an Annual Report....more

Monitoring Of Third-Party Agents And Distributors

by Michael Volkov on 4/3/2013

Try to imagine what DaVinci said to himself when he painted his last brush stroke on the Mona Lisa. Or consider what Tolstoy muttered to himself when he put down his pen after writing the last word of War and Peace....more

Hospitals: Audits And Compliance

by Michael Volkov on 4/2/2013

Hospitals are under intense scrutiny. The federal government knows that one sure way to reduce healthcare costs is to get hospitals to lower their costs. Hospitals feel the pinch given the need to generate revenue but know...more

Criminal Sentencing Of Corporations

by Michael Volkov on 4/1/2013

Contrary to former candidate Romney’s view of the world (“Corporations are people”), you cannot put a company in jail. Try as you might, it just can’t be done....more

The Truth Behind Gifts, Meals And Entertainment Enforcement

by Michael Volkov on 3/29/2013

It is time for everyone to take a deep breath. The DOJ/SEC Guidance could not have been clearer. The message to companies – stop devoting so much time to building, tinkering with, and monitoring their policies governing...more

Third Party Risks And Internal Auditors

by Michael Volkov on 3/27/2013

You remember the corny song – “People who need people are the luckiest people in the world.” For a Chief Compliance Officer that saying is particularly important when it comes to third party risks. CCOs need their...more

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Tell A Story To Drive Compliance

Demonstrating The Effectiveness Of Your Compliance Program

Scam Artists From Texas And Compliance Risk Management

The Compliance Stepchild: Antitrust

Turning CCOs Into Business Partners

Leveraging The Board And CEO Relationship To Improve Compliance

Improving Your Anti-Corruption Training Program

The Three Amigos/Amigas: Compliance, Audit And Legal

SEC Sanctions Fund Trustees for Inadequate Disclosures and Failure to Follow Compliance Policies

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

The Hatfields And The McCoys: CCOs And GCs?

The Danger Of FCPA “Proactive” Investigations

Got 20 Minutes? Spicing Up Compliance Training

The Importance Of A Board Compliance Committee

SEC Highlights Compliance and Ethics for Broker-Dealers

An Independent CCO Is A Compliance Program Requirement

Why Eat Your Words When You Can Eat a Peach?

Empowering The Chief Compliance Officer

Three Compliance Interviews on April 3

CFTC No-Action Relief for Compliance Reporting

Monitoring Of Third-Party Agents And Distributors

Hospitals: Audits And Compliance

Criminal Sentencing Of Corporations

The Truth Behind Gifts, Meals And Entertainment Enforcement

Third Party Risks And Internal Auditors

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

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