Chief Compliance Officers

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Ty Cobb and the Compliance Performance Appraisal Review

Today we celebrate greatness, in the form of one of the greatest baseball players ever, with the anniversary of the birthday of Ty Cobb. Coming up to the majors as a center fielder for the Detroit Tigers in 1905, he emerged...more

NAVEX Global’s Most Popular Ethics & Compliance Matters Articles from 2014

This year, we relaunched our blog with the goal of better serving the ethics and compliance community, providing deeper insights on topics that matter most to E&C professionals, as well as best practices and practical steps...more

Gifts, Meals and Then . . . FCPA Enforcement

Life can be very humbling. The SEC has definitely humbled me. For years now, I have been claiming that companies spend too much time worrying about gifts, meals and entertainment expenses under the FCPA, rather than...more

FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom [Video]

In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement...more

The Eve of Destruction and Tone at the Top – You Are Who Say You Are

In 1965 the single Eve of Destruction was released. It was written by an 18 year old named Phil Sloan and was sung by former member of the New Christie Minstrels named Barry McGuire. To top it off, it was produced by Lou...more

6 Questions To Ask Before An Internal Investigation

Every company, large or small, will eventually face a problem that requires an internal investigation. Boiled to its essence, an internal investigation is really nothing more than a way to obtain information to avoid or solve...more

Seven Things DOJ Insiders Expect Organizations To Know (and Do) About Antitrust Compliance

For most organizations, the risk of violating antitrust laws is real. But when it comes to the most serious of antitrust violations, such as cartels and significant price fixing schemes, there is often an “it won’t happen...more

Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

Hiring and Promotion in Compliance – Wait for Great

The role of Human Resources (HR) in anti-corruption programs, based upon the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act, is often underestimated. I come from a HR background and practiced labor law early in my...more

Seven Key Actions to Accelerate Your Ethics and Compliance Program

We always hear (and talk about) the rise in the compliance profession. Yes, there is increased demand for CCOs and compliance officers. More lawyers are transitioning into the compliance profession....more

The FCPA Compliance and Ethics Report-Episode 114-Doing Compliance, The Book [Video]

In this episode, I discuss my recently released book, Doing Compliance: Design, Create and Implement an Effective Anti-Corruption Compliance Program...more

Seamus Heaney and Compliance With a Seat at the Table

I have long been fascinated with the Irish poet Seamus Heaney. I came to know him thought his 1999 translation of Beowulf. While I was aware that he had been awarded the 1995 Nobel Prize for Literature, I did not know his...more

Focusing on the Disconnect: Mid-Level Managers and Handling of Employee Concerns

We all have heard the problem: Employees want to report their concerns directly to their immediate supervisors (unless the problem relates to the immediate supervisor); Mid-level managers complain that they do not know how to...more

On Compliance Leadership: From Edward VIII to LeBron James

On this day in 1936 King Edward VIII became the first English monarch to voluntarily abdicate the throne. He chose to abdicate after the British government, public and the Church of England condemned his decision to marry the...more

How To Mitigate Compliance Risk With Effective Investigations Of Whistleblower Hotline Reports

I recently started watching the first season of the television show True Detective. If you’ve seen the show, you’ll know that Matthew McConaughey’s character, “Rust” or “Rustin”, is known for his master interrogation skills....more

FinCEN Fines Small Credit Union for BSA Violations

On November 25, FinCEN fined a small Florida-based credit union $300,000 in civil monetary penalties for violating the Bank Secrecy Act (BSA). From 2009 through 2014, FinCEN charged that, among other deficiencies within its...more

Kickbacks and Bribery

Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues....more

Bobby Keys, the Rolling Stones and Establishing Trust

Bobby Keys died last week. What you probably did not know was that Keys was a Texan so we get to claim him. He was the saxophonist for the Rolling Stones and a number of other serious rockers. ...more

Compliance Attitudes in High-Risk Markets

A Chief Compliance Officer has a direct responsibility to promote the company’s business. That sounds like a controversial statement but it is not. Every officer and employee of a company has that responsibility....more

Recent SEC Enforcement Actions Highlight Importance of Robust Insider Trading Compliance Policies

Recently the SEC announced enforcement actions which highlight the importance of complying with the beneficial ownership reporting requirements under Sections 13(d), 13(g) and 16(a) of the Securities Exchange Act of 1934, or...more

Lawyers and CCOs on the Front Line: Who’s on First? What’s on Second

I never thought the day would come but it has – I have figured out a way to make Abbott and Costello relevant to the compliance profession. We all know their famous routine – “Who’s on First?” ...When it comes...more

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

Ethical Culture: Action Speaks Louder Than Words

“Action speaks louder than words but not nearly as often” – Mark Twain If you are too busy to read my posting, all I ask is that you read the Mark Twain quote and apply the message to creating an ethical culture....more

Building the Business Case for an Ethics and Compliance Program Budget Increase

Compliance departments, in general, don’t have a reputation for being lavishly funded. While ethics and compliance program budgets are slowly growing, as shown in recent research presented by CEB, the Deloitte 2014 Compliance...more

Sherlock Holmes and Innovation in the Compliance Function – Part IV, The Valley of Fear

Today I conclude my dual-themed week of blog posts featuring Conan Doyle’s four Sherlock Holmes novels and innovation in the compliance function. As the compliance profession matures and we move into what I call the era of...more

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