News & Analysis as of

Internal Audit Functions

Have you started auditing your contracts with your service providers that handle EU personal data? UK Information Commissioner’s...

Many companies have started the potentially lengthy process of auditing their service provider contracts to make sure that they comply with the requirements of the General Data Protection Regulation, which comes into force on...more

Preliminary Planning for the 2018 Proxy Season

Rule 14a-21(b) requires a say-on-pay frequency vote every six years. Many issuers included a frequency vote in their 2017 proxy because they were subject to the initial rules when they became effective for shareholders’...more

Day 8 of One Month to More Effective Continuous Improvement-the Culture Audit

by Thomas Fox on

What is organizational culture? Eric Feldman, SVP at Affiliated Monitors has said it comprises the mission, vision and values of an organization. A similar way to consider it might be as a company’s values, visions, norms and...more

Don’t Let Data Walk Out the Front Door: 7 Security Measures for Preventing Data Loss When Employees Leave

by Exterro, Inc. on

With all the news surrounding data breaches and information leaks, it’s easy to overlook the fact that the number one path sensitive/confidential information illegally enters the public domain is when employees leave their...more

Evolution of Your Compliance Program

by Thomas Fox on

One of the most consistent themes from the Department of Justice (DOJ) regarding Foreign Corrupt Practices Act (FCPA) compliance programs has been continuous evolution. As far back as 2009, I heard Lanny Breuer say that your...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

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

Ensuring Compliance with Controls

by Michael Volkov on

Let’s start with some basics – a public company is required to implement a set of internal controls. A compliance program is a critical part of a company’s internal controls. A company’s compliance program is only as...more

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

by Thomas Fox on

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...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

Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance

by Thomas Fox on

I conclude this month’s series inspired by an article in the Harvard Business Review, entitled “Does Management Really Work?” by Nicholas Brown, Raffaella Sadun and John Van Reenen. I found the article very useful because it...more

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

by Thomas Fox on

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...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

Hong Kong – The new independent insurance regulator takes charge

by Hogan Lovells on

It has been announced that the new Independent Insurance Authority for Hong Kong (“IIA“) will assume its functions on 26 June 2017 (the “Commencement Date“), replacing the Office of the Commissioner of Insurance....more

Compliance and Financial Audits – Distinctions With Substance

by Michael Volkov on

Chief compliance officers and internal auditors are natural friends and allies. In the corporate governance world, they share many common interests....more

Thawing the ICE: Using Internal Audits to Reduce Form I-9 Exposure

As the 100-day mark of President Trump’s tenure approaches, it’s clear that the new administration intends to take a tough, aggressive approach to immigration enforcement – and employers are sure to feel the heat. The...more

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

by Michael Volkov on

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

When It Comes to Documentation, Smart Companies Behave Like Every Day Is Audit Day

by NAVEX Global on

Audits are part of nearly every ethics and compliance program. They come from the Internal Audit Department, outside auditors testing control systems and processes, and in some cases, government regulators evaluating the...more

Insight from CFPB Regarding Employee Incentives in the Wake of Wells Fargo Consent Order

This past November, in the wake of the Wells Fargo debacle, the CFPB issued a Compliance Bulletin which addressed employee incentives and the consumer risks associated with them. CFPB Compliance Bulletins are non-binding...more

Compliance Trends and Predictions for 2017

by Michael Volkov on

The past year was another great success for the compliance profession and related technologies. Compliance continues to grow as the “professionalization” of compliance continues to skyrocket. As my good friend Donna Boehme...more

Do Not Repeat the Mistakes of Your Diva

by FordHarrison on

Preparation pays off. While it may be well known that “practice practice practice” gets you to Carnegie Hall, it appears you don’t even need to do the sound check to play Times Square on New Year’s Eve. Mariah Carey’s...more

How to Prepare for New Equal Pay Requirements

by NAVEX Global on

The Equal Pay Act in the United States dates back to the early 1960s. But its enforcement—and the conversation about equal pay issues around the globe—requires close watching in the next few years....more

Private Right of Action under CASL coming July 2017

by Dentons on

Canada’s Anti-Spam Law came into force on July 1, 2014. Since then, all eyes have been on the Canadian Radio-television and Telecommunications Commission (CRTC) for decisions concerning CASL violations. In the cases made...more

Federal Minimum Salary Increases for Exempt Workers Take Effect December 1, 2016

by Fenwick & West LLP on

If you have not audited your exempt employee pay practices for compliance with the federal Department of Labor’s rules announced earlier this year, you have just under two weeks to do so. Starting December 1, 2016, the...more

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