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Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 1 – A Case Study in Failure

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Society of Corporate Compliance and Ethics...

What the Board Should Be Asking About the Compliance Program

"What else should the board be asking about the compliance group?” It’s a good question in general and the tile of a session at the SCCE Compliance & Ethics Institute, which will be held September 22-25, 2024 in Grapevine,...more

Society of Corporate Compliance and Ethics...

Don’t be afraid

A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more

The Volkov Law Group

Compliance Titles and Responsibilities

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Let me start with yet another profound grasp of the obvious — leadership requires many important interpersonal and intellectual capabilities.  I do not intend to list the important ones right now but leadership requires an...more

The Volkov Law Group

Compliance by Fear: An “Old” Mindset

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Compliance by fear is not an effective strategy for promoting the purposes of a compliance program – to enhance a company’s ethical culture and compliance performance, and to prevent and deter misconduct. A proper calculation...more

Thomas Fox - Compliance Evangelist

Leadership Lessons from Abraham Lincoln (UPDATED)

In honor of President’s Day 2021, I look at some leadership lessons from Abraham Lincoln. In a New York Times (NYT) article, entitled “Lincoln’s School of Management”, Nancy F. Koehn, a historian at the Harvard School of...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Southern California Regional Compliance & Ethics Conference - January 22nd, 8:25 am - 5:30 pm PST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Thomas Fox - Compliance Evangelist

The Role of HR in Creating an Ethical Culture

The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

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On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

The Volkov Law Group

The New Test for CCOs

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These are inspiring times for the compliance profession. Looking back on the last ten years, it is amazing to observe the growth and influence of the compliance profession. Many of the original advocates for the compliance...more

Parker Poe Adams & Bernstein LLP

Practical Suggestions on ‘Why Compliance Programs Fail’

I recently cracked open my Harvard Business Review to the article on “Why Compliance Programs Fail.” I read with great interest the authors’ theory on how weak, milk-toast metrics can result in check-the-box, paper-only...more

The Volkov Law Group

Putting Ethics Back Into Compliance (Part IV of IV)

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My final posting on this week’s ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger...more

The Volkov Law Group

Ominous Signs for the Future of the Compliance Profession

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As we celebrate Ethics and Compliance Week in 2017, I wanted to offer my own assessment of where the compliance profession stands and the challenges facing the profession for the future....more

The Volkov Law Group

HR and Compliance: Working Together to Hire Ethical Employees

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Human resources and compliance professionals share many common objectives and interests. They need to coordinate and operationalize their joint interests in a variety of ways....more

Thomas Fox - Compliance Evangelist

Astros Garner First World Series Win – Execution of Compliance in the Middle

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

Thomas Fox - Compliance Evangelist

Will Your Assets Be Stranded? The Risk Management Process in ESG and Compliance

State Street Global Advisors (SSGA) is a company which engages in US and broader international institutional investing, largely on behalf of its clients. Some of the areas it focuses on include environmental, sustainability...more

The Volkov Law Group

FCPA Risks and Acquisition Integration Challenges

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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

Thomas Fox - Compliance Evangelist

Clarence Darrow, the Scopes Monkey Trial and Leadership

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

Thomas Fox - Compliance Evangelist

GHBER Tribute to Jay Martin

This Thursday 19th May, the Greater Houston Business and Ethics Roundtable (GHBER) will hold its first Ethics and Compliance Awards Dinner in honor of the 20-year anniversary of the organization’s founding. We will award the...more

Thomas Fox - Compliance Evangelist

Mother Maybelle and Effecting Change in an Organization

Today we celebrate great American music and honor one of its founders, Mother Maybelle Carter who was born on this day in 1909. Now known more as the mother of June Carter Cash, the wife of Johnny Cash, Mother Maybelle was a...more

Thomas Fox - Compliance Evangelist

Good-Bye to Captain Hocken and Scaling Up Your Compliance Program

George Kennedy died this week. He was one of the few actors who went from playing tough guys to being a hit in comedies. According to his obituary in the New York Times (NYT), Kennedy played “vicious killers, bumbling lawmen,...more

The Volkov Law Group

Embedding the Compliance Message in Middle Management

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Chief compliance officers and senior executives wrestle with strategies to spread and embed important compliance messages. A CEO and senior executives can spread a compliance message but they are always battling competing...more

The Volkov Law Group

Financial Institutions and a Lack of Ethics

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If there is one industry that needs an ethics overhaul, it has to be the financial industry. The list of transgressions continues to grow – AML/sanctions, LIBOR, Foreign Exchange Currency Cartels and Market Manipulations,...more

Thomas Fox - Compliance Evangelist

What’s the Password for Compliance? Swordfish and Lessons for the CCO

I continue my exploration of the Marx Brothers this week by looking at their most successful commercial film made for Paramount, Horse Feathers. While Duck Soup is and always will be my favorite film due to its overall and...more

The Volkov Law Group

Avenues for Reporting Employee Concerns

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We all like to make things more complex or difficult than they need to be. Consider that a life lesson that we can share with our children, assuming they are even listening to us these days....more

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