News & Analysis as of

Encouraging Communication Of Employee Concerns

One of the hardest issues for compliance professionals is encouraging employees to raise concerns about ethics and compliance issues. It has become even more difficult when the government establishes whistleblower programs...more

Interviewing in the Context of Workplace Investigations

As an ethics and compliance professional and investigator, I have been intrigued by the recent media coverage of wrongful convictions. Also, the stories reminded me of a fascinating article in the New Yorker magazine a few...more

Machiavelli For Chief Compliance Officers

Last year was the 500th anniversary of the publication of one of the most significant books on political theory ever written, The Prince by Niccolò Machiavelli. Just how evil do many people view the treatise? Consider that...more

Startling ERC Survey Findings on Misconduct, Retaliation – Is Your Corporate Ethics Training Working?

Last spring I was speaking with several of our clients at an event in Atlanta and the discussion was around ethics and compliance program effectiveness. Specifically, these clients were saying that more and more often they...more

Remember The Alamo: Analogy For Compliance Officers?

Today is the anniversary of the most historic day of many in the history of the great state of Texas, the date of the fall of the Alamo. While March 2, Texas Independence Day, when Texas declared its independence from Mexico...more

FCPA Compliance and Ethics Report-Episode 3-Interview with Marie Patterson, Vice President of Marketing for Hiperos [Video]

In this episode of the FCPA Compliance and Ethics Report, I visit with Marie Patterson, VP of Marketing for Hiperos. We discuss the management of third parties by a commercial entity throughout the life cycle of the...more

Four Critical Questions For Assessing Compliance Communications With The Board Of Directors

If you want to know how well an ethics and compliance program is doing, the best indicator is to review the communications between the Chief Compliance Officer and the Board of Directors, usually the Audit Committee....more

Ethics & Compliance: Our Give and Take with the Government

Last year, the U. S. Securities and Exchange Commission (SEC) indicated that it would be looking for additional ways to support the work of Ethics and Compliance Officers. Their stance came in part as a result of the Johns...more

Diagnosing A Compliance “Failure”

Life is filled with ups and downs. Compliance officers know this and are familiar with riding the roller coaster. Compliance “failures” are inevitable....more

2014 Trends: #9 Proving the ROI of Ethics and Compliance

The final trend we’ll cover as part of our Top 10 Trends series will appear next week (we’re hosting a webinar on all ten trends next Thursday), but today we'll cover #9 - a topic critical to the ethics and compliance...more

Chief Ethics And Compliance Officers – Reasonable Expectations

Chief Ethics and Compliance Officers are giddy these days – the push for empowerment: independence and resources is continuing to succeed. Of course, the transformation will take time....more

The Zen of Compliance Best Practices is Intrinsic and Ethics-Based

No compliance officer worth her salt would argue with this statement: “We strive to maintain an ethics-based organization.” But compliance teams, with all of the internal and external scrutiny, with all the regulations and...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

Benedict Arnold And How To Be A Game-Changer In Compliance

Today is the anniversary of the birth of one of the most notorious Americans of all-time: Benedict Arnold. His name is synonymous with the word traitor in the United States and in many ways more derogatory....more

Why Your Code Must Be Your Ultimate Policy

I recently had an opportunity to participate in a discussion about what the next generation Code of Conduct looks like and why organizations should care. This topic has been brought up by many organizations that I interact...more

A New Approach To Compliance: “Informed” Risk And Resource Allocation

The compliance field has had an incredible five years. From backwater offices and responsibilities, CCOs are now taking a seat at senior management tables to provide important risk-based assessments and policies to enhance...more

A Lot Of Pain In KC And Leadership In Compliance

While sports fans can relive the triumphs and tragedies of their team’s ad naseum corporate leaders cannot not afford to do so. One key resource I have found, for not only the ideas of what a leader needs to do but the...more

Little Help From My Friends – Predictions For Ethics And Compliance In 2014

When it comes to predicting ethics and compliance trends and events for the new year, I admit I needed some help. So I reached out to two leading ethics and compliance specialists in the industry – Donna Boehme and Michael...more

The Real Purpose(s) Of A Compliance Program

You can label this posting as another in the series of profound grasps of the obvious. Chief Compliance Officers rely on public relations skills – they have to convince their organizations to embrace a culture of ethics and...more

My Favorite Blog Posts From 2013

One of the best things about the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and other anti-corruption practice areas is the top notch quality of commentators. While Mike Volkov regularly derides the FCPA paparazzi...more

The CCO – Not The CEO – Creates An Ethical Culture

Consider it one of my (many) pet peeves – companies claim they have an “ethical” culture and cite the consistent statements by the CEO of his or her commitment to “ethics and integrity.” That’s it, that’s all, we have an...more

Sammy Baugh In 1943: Do It The Right Way

2013 is the 70th anniversary of one of the greatest individual seasons in pro football. In 1943, Sammy Baugh, playing for the Washington professional football team, had what Sports Illustrated said one of the greatest...more

The Texans Are 2-7: What Is Missing from Your Compliance Program?

I usually do not write about the Houston Texans because (1) unlike the sad sack Astros, they are not often relevant enough to care about and (2) they usually are relatively well-run. They continue to be not relevant this...more

What's the One Thing Missing From Your Corporate Compliance Program?

What's the one thing missing from most corporate compliance programs? For a legal perspective, that's the question we put to corporate attorneys writing on JD Supra, asking each to commit to just one essential element...more

SAC Insider Trading Case May Hit Closer to Home than You Think

This week’s announcement that SAC Capital Advisors will pay a record-breaking penalty of $1.8 billion (USD) for insider trading violations may not have been a surprise to anyone following the case - after all, the hedge...more

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