News & Analysis as of

Ethics Compliance

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

Unfair and Unbalanced-Episode 18 [Video]

by Thomas Fox on

In this episode, Roy Snell and myself discuss how incentives are integral to the compensation plans of a wide range of workers. Many experts point to their value in rewarding behavior that is in the interest of the...more

Operationalizing Compliance Through Your Tone in the Middle [Video]

by Thomas Fox on

One of the ways that Human Resources (HR) can help to operationalize compliance is to assist each level of an organization to have a proper tone. While the top of an organization rightly gets much of attention, the tone about...more

Day 18 of One Month to Better Compliance Through HR- Using Promotions to Operationalize Compliance [Video]

by Thomas Fox on

The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antithetical to HR, the company...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

From Bottom Bunk to Top Mind

I recently had the honor of being named to Compliance Week’s list of Top Minds for 2017, earning the title of “The Great Communicator” from Bill Coffin, Donna Rice, and the CW team....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

This Week in FCPA-Episode 53, the I left my heart in San Francisco edition [Video]

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian President Temer comes under corruption fire? 2. The turmoil at FIFA continues as FIFA’s...more

FCPA Compliance Report-Episode 327, Pat Harned on Highlights from the ECI 2017 Conference [Video]

by Thomas Fox on

In this episode, I visit with Pat Harned, Chief Executive Officer of the Ethics and Compliance Initiative on the recently concluded annual conference. She discusses the speech of Attorney General Jeff Sessions and the panel...more

The “Rock-Star Exception” Is More Expensive Than You Think

by NAVEX Global on

One of the hallmarks of a healthy organizational culture is that it makes no exceptions or excuses for inappropriate behavior. It is simply not possible to maintain workplace integrity if certain individuals are excused for...more

Day 11 of One Month to Better Compliance Through HR-the Fair Process Doctrine [Video]

by Thomas Fox on

Procedural fairness is one of the things that will bring credibility to your Compliance Program. Today it is called the Fair Process Doctrine and this Doctrine generally recognizes that there are fair procedures, not...more

Promoting Ethics on the Front Line

Encouraging employees to ‘do the right thing’ and apply their organisation’s core values is of utmost importance. How can this be achieved in practice by organisations that employ thousands of employees around the world, who...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

The King’s Speech…Communicating Your Compliance Story

by Thomas Fox on

On this day 80 years ago, George VI and his consort, Lady Elizabeth, are crowned king and queen of the United Kingdom. They were crowned after the King’s brother, Edward VII had abdicated the throne for the woman he loved,...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

AG Jeff Sessions Left Compliance Officers with More Questions than Answers … and an Invitation

by NAVEX Global on

Attorney General Jeff Sessions was a keynote speaker at the 2017 Ethics & Compliance Initiative’s Annual Conference last week. Whatever your politics are, it was important that we hear from him on his priorities for...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

The Importance of Trust in the Age of Weaponized Transparency

by NAVEX Global on

In my last post about organizational trust, we looked at lessons learned about trust from one of the largest organizations of all: the U.S. military. The main concept was that in large organizations, senior executives should...more

Day 1 of One Month to Better Compliance Through HR-the Role of HR in Operationalizing Compliance [Video]

by Thomas Fox on

This month, I will consider the role of Human Resources (HR) in operationalizing a best practices compliance program. I have long advocated for a greater role of Human Resources (HR) in a compliance program. Indeed, one sign...more

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

20 Questions to Ask when Prioritizing Your Policy Development Efforts

by NAVEX Global on

Having too many policies can burden your organization, but having too few exposes it to unnecessary risk. That means we need to prioritize which policies we will develop (or revise) first. As a rule of thumb, policies are...more

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