News & Analysis as of

Ethics Chief Compliance Officers

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 [Video]

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

The Revolution in Compliance Training – It is Not Just About Your ABCs

by Michael Volkov on

A CCO never feels like he or she has caught up on compliance program requirements. As soon as one new best practice is identified, a CCO blinks for a moment and then there is a new best practice for them to consider....more

How to garner a NPA and Declination

by Thomas Fox on

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program as there where two public declinations granted by the DOJ for companies...more

Leadership Lessons from the Movies

by Thomas Fox on

Today, I wanted to consider some of the recent leadership lessons I have explored on my podcast, 12 O’Clock High, a podcast on business leadership. In the series, host Richard Lummis and myself, mined some of our favorite...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

by Michael Volkov on

Here is a profound grasp of the obvious – Lawyers can be difficult people. Some like to condemn the profession in its entirety (and carry with them a collection of lawyer jokes). As an attorney, I beg to differ. Many...more

LRN Compliance Program Effectiveness Report: Part III

by Thomas Fox on

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

by Thomas Fox on

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Managing Your Ethical Culture: Measure, Intervene and Remediate

by Michael Volkov on

In the wake of ever-constant business scandals (e.g. ZTE, VW, Takata, Odebrecht), chief compliance officers have to refresh their approach and strategy. Everyone agrees, or at least I think they should agree, that a company’s...more

Creation of Roundabout and Operationalization of Compliance

by Thomas Fox on

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

How Effective is Your Corporate Compliance Program?

On February 8, the Fraud Section of the United States Department of Justice (DOJ) posted on its website a document entitled “Evaluation of Compliance Programs” (the “Guidance”). This is the first formal guidance issued by the...more

Under the Dark of Night, DOJ Moves the Compliance Ball (Part I of IV)

by Michael Volkov on

In an unusual move, the Justice Department issued an important document in the dead of night – Evaluation of Corporate Compliance Programs. We have no explanation from the Justice Department for the issuance of this...more

The FCPA Pilot Program Disciplinary Standards (Part II of II)

by Michael Volkov on

Returning to the FCPA Pilot Project requirements for timely and appropriate remediation, the Justice Department added three new elements, one of which reinforces the CCO “independence” requirement. The two other elements for...more

Unpacking the Justice Department’s Compliance Remediation Standards (Part I of II)

by Michael Volkov on

The Justice Department has a lot to be proud about when it comes to its FCPA enforcement program. In one area in particular – promoting effective ethics and compliance strategies – DOJ’s FCPA prosecutors have played a...more

Effective Ethics and Compliance Training

by Thomas Fox on

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Leadership Lessons from Mutiny on the Bounty

by Thomas Fox on

In honor of February and its traditional run up to the Oscars, in my podcast on business leadership, 12 O’Clock High, a podcast on business leadership, I am exploring leadership lessons from Oscar-winning Best Pictures. In...more

External Perception of Your Internal Culture Is a Big Deal: What Uber’s Problems Have Taught Us about Reputation

by NAVEX Global on

Ethics and compliance officers might often feel like your company’s corporate culture gets tied into knots, with so many groups imposing demands on your organization’s behavior. But really, a better turn of phrase here...more

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