Risk Assessment Compliance

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Why Reputation Risk is Quickly Climbing the Ethics and Compliance Priority List, Part 3 | Beyond Compliance Training

So far in this series, we’ve discussed why companies are adopting a more public focus on ethics and compliance, how reputational risk can impact a company and its brand, and the first three elements of a five-part framework...more

Cybersecurity Oversight: What is a Board of Directors to Do?

Cybersecurity and the risks of data breaches figured prominently at the 35th Annual Ray Garrett Corporate and Securities Law Institute held April 30, 2015, at Northwestern Law School in Chicago. Participating in a panel...more

"HHS OIG Issues New Compliance Oversight Guidance for Boards of Directors"

On April 20, 2015, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published its “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the Guidance).1...more

How Smart, Connected Due Diligence Systems are Transforming Third Party Risk Management

The compliance field is in the early stages of a paradigm shift on managing due diligence—moving from a data drought to a data flood. Today’s compliance manager has to figure out how to proactively and continuously manage,...more

Reinventing Compliance Program Metrics

One of many pet peeves I have in the compliance space is the lack of creativity in compliance program measurement. Chief Compliance Officers have to take a fresh approach to this issue....more

FCPA Compliance and Ethics Report-Episode 153-Doing Compliance in an Economic Downturn [Video]

The energy industry is in turmoil from the drop in the price of oil from $100 down to around $50 per barrel. Many energy companies have laid off up to 30% of their workforce. What can you do from the compliance perspective...more

A Neglected Compliance Task: Program Assessments

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

Navigating FCPA Risks in Global Private Equity Ventures

In light of the global nature of the private equity industry, minimizing Foreign Corrupt Practices Act (FCPA) risks is an important consideration for private equity firms and their portfolio companies. ...more

Anti-bribery compliance in the UK - check for 'red flags' on any acquisition

When one company acquires another, it has long been common practice for the purchaser to carry out commercial due diligence upon the target company. However, anti-bribery and corruption (ABC) due diligence is often overlooked...more

FCPA Compliance and Ethics Report-Episode 147-Prof. David Orozco on the use of compliance as a business strategy [Video]

In this episode I visit with Florida State University Professor David Orozco about his recent article on the use of corporate legal as a business strategy and its implications for the compliance practitioner. ...more

Seven Training Imperatives to Address Your Biggest Cyber Security Risk: Employee Behavior

One of your best defenses against a cyber attack? Your employees. Make sure they are trained on their role in protecting your organization. There are pros and cons to the digital world that we all live in. Pros include...more

What Scuba Diving Can Teach You About Policy Management: Three Key Lessons

What do policy management and scuba diving have in common? The need to mitigate risk, use the right equipment and prioritize training. You might not imagine that scuba diving and policy management could have much in...more

Board Reporting: Elevating Your E&C Program & Engaging the Board

In This Presentation: - The Board’s Roles and Compliance Responsibilities - The Board Report & Briefing vs. Training - Important Considerations for your Board Report - Case Study - How Can I Tell if my Board is...more

Practical Advice on Risk and Compliance Program Assessments

Sometimes the compliance industry makes things harder than they really need to be. As a result, Chief Compliance Officers are left to modify and transform practices and tools to fit the real world. I understand why CCOs do...more

Bribery, Beneficiaries and Guilty Feelings (or lack thereof)

Given the response to my recent Q and A with Jamie-Lee Campbell on “Culture Corrupts,” which from an analytics and engagement perspective, was one of my most read pieces on a global basis since I started blogging, I decided...more

Farewell to Mr. Spock and Risk Assessment Under COSO

Leonard Nimoy died last Friday. He will be forever associated with the role of Mr. Spock in the original Star Trek television show which premiered in 1966. The original series ran for only three years but had a full life in...more

Goodyear’s Settlement with the SEC Emphasizes the Importance of FCPA Due Diligence in M&A Transactions and of Having a Robust...

On February 24, 2015, Goodyear Tire & Rubber Co. agreed to pay more than $16 million to settle charges that two of its subsidiaries allegedly paid $3.2 million in bribes that generated $14,122,535 in illicit profits. The SEC...more

FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen [Video]

In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more

COSO and Internal Controls – Part V

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

Selfie-Sticks and Risk Assessments

Greetings from Venice and a big thanks to Joe Oringel at Visual Risk IQ for allowing my to post his five tips on working with data analytics while I was on holiday in this most beautiful, haunting and romantic of cities....more

Improving the Message of Ethics and Compliance

To succeed in life, you need two things: ignorance and confidence – Mark Twain - I have a problem with writers, columnists, consultants, bloggers and anyone else who puts a pen to paper (as we used to say) on ethics...more

2015 Trends: #10 Cybersecurity: A Risk that Needs to be on Your Ethics and Compliance To-Do List

The starting point for every ethics and compliance program must always be an analysis of the ethics and compliance risks faced by the organization. In that light, it’s important to listen to James Comey, Director, U.S....more

2015 Trends: #8 Top Whistleblowing Priorities for Compliance Professionals

Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more

Both Sides Now and Asking the Right Compliance Questions

One of my favorite singers has always been Judy Collins. Like most of us, I was introduced to her through her interpretation of Joni Mitchell’s song Both Sides Now which she released in 1967. Joni Mitchell did not record her...more

Reconciling Sales Strategy With FCPA Compliance

When Ethical Boardroom asked me to contribute an article on the Foreign Corrupt Practices Act (FCPA) and international sales strategies, I thought it might be interesting to include an organisational change dimension in...more

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