News & Analysis as of

Ethics Chief Compliance Officers

FCPA Risks and Acquisition Integration Challenges

by Michael Volkov on

Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more

Clarence Darrow, the Scopes Monkey Trial and Leadership

by Thomas Fox on

Today we honor one of the ‘Trials of the Century’ from the 20th century, as on this day in 1925, the Scopes Monkey Trial ended with defense attorney Clarence Darrow giving one of his greatest closing arguments, asking for his...more

CCO’s and Delusions About a Company’s Ethical Culture

by Michael Volkov on

It is easy to say something and convince yourself it is true. As George Costanza advised Jerry Seinfeld when Jerry had to take a polygraph examination when he failed to admit that he watched “Melrose Place,” “Remember Jerry....more

The Importance of Compliance Program Audits

by Michael Volkov on

Chief compliance officers spend a significant amount of time comparing their compliance programs with other companies’ programs. CCOs often find solace when benchmarking their respective programs against other companies’...more

CCO Leadership: Lessons from Kaiser Permanente

by Thomas Fox on

One thing every Chief Compliance Officer (CCO) will face is multiple stakeholders. The more compliance is operationalized the more sensitized this issue will become. Yet the centralized control that many business leaders have...more

Incorporating Employee Storytelling into Your Compliance Marketing

by Thomas Fox on

As you might suppose I read quite a bit. One of the pleasures I receive each month is when the copy of the MIT Sloan Management Review arrives. I also find the articles highly topical and present ways to consider new...more

CCOs and Resources: Put Your Money Where Your Mouth Is!

by Michael Volkov on

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more

Are Risk Assessments Just a Report on the Obvious?

by Michael Volkov on

If you give a Chief Compliance Officer truth serum and ask him/her whether they believe a risk assessment is valuable, what do you think the CCO say? Let’s start with the cynical side – not that I am a pessimist. Many CCOs...more

5 Telltale Signs of a Weak Corporate Culture

by Michael Volkov on

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the...more

This Week in FCPA-Episode 57, the Father’s Day Edition

by Thomas Fox on

This week, as their tribute to their Dad, we are guest hosted by Jay’s daughters, Millie and Michela. They lead us through a wide-ranging discussion on some of the week’s top compliance related stories, including: 1. The...more

Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress

by Michael Volkov on

Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These...more

The Uber Board Report – Part I

by Thomas Fox on

On Tuesday, the law firm of Covington & Burling LLP (Covington), released its long-awaited report (Report) to the Special Committee of the Board of Directors of Uber Technologies, Inc. (Uber). It is truly one of the most...more

A CCO’s Challenge: How to Convince a CEO to Embrace Compliance

by Michael Volkov on

A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he...more

The Stoic's Guide to Compliance

by Thomas Fox on

One thing about successful Chief Compliance Officers (CCOs) and other compliance practitioners is they can take in severe news, keep calm and carry on. In a keynote speech to the SCCE Compliance and Ethics Institute, Jenny...more

The Spirit of Compliance

by Thomas Fox on

One of my weekend pleasures is reading Peggy Noonan’s column in the Wall Street Journal (WSJ). Each week is filled with wit and insight and some of the finest writing around. This past week, in an article entitled “Why...more

Compliance into the Weeds-Episode 40, COSO ERM Framework Update

by Thomas Fox on

In this episode Matt Kelly and I take a deep dive into the revisions to the COSO ERM Framework, which were based on comments by practitioners. We consider the role of culture and risk, the integration of the COSO ERM...more

Operationalizing Compliance: Part V – Controller’s Office

by Thomas Fox on

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

The Compliance Profession Needs to Adopt Professional Standards

by Michael Volkov on

Those who regularly read my blog have heard me often cite the need for the compliance profession to adopt professional standards. With the rise of the profession, and the expectations placed on the shoulders of compliance...more

Operationalizing Compliance: Part IV – Internal Audit

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

by Thomas Fox on

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture

by Thomas Fox on

The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical culture is an important step...more

MoneyGram CCO Pays Civil Penalty

by Michael Volkov on

Like any other profession, the compliance profession is not immune to bad apples. Lawyers know the law but have been criminally prosecuted for breaking the law. The same goes for compliance professionals....more

Don’t Outsmart Yourself: AI and Compliance

by NAVEX Global on

I’m a big fan of artificial intelligence. The older I get, the more I appreciate that real intelligence needs all the help it can get. Corporate ethics and compliance officers, however, need to pause before betting big on AI...more

The Compliance Profession and the Demand for “Results”

by Michael Volkov on

Compliance professionals are riding high. They are the darlings of the corporate governance world, commanding higher salaries, C-Suite positions with access to senior leadership and the board, and an empowered position within...more

The Trump Administration: The Business Impact

by Thomas Fox on

If we do not speak up, there may not be an opportunity later. ...more

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