Risk Assessment Compliance

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2016 Trends #2: Transitioning to a More Global Center of Gravity for Ethics and Compliance

Today, many ethics and compliance professionals, no matter where we’re located, find it to be important to keep up-to-date on the latest news from the European Union courts, the U.K.’s Serious Fraud Office and international...more

Star Wars Week Part I – How do You Evaluate a Risk Assessment?

Today I begin a series of Star Wars themed blog posts to celebrate the upcoming release of the next entry in the Star Wars franchise, Episode VII – The Force Awakens. Please note that I will only use the first three movies,...more

Applying Practical Strategies to Supply Chain Risk

Compliance Officer can get so overwhelmed with risks that it is hard to keep their focus on priorities. Risks are everywhere and no compliance program can address every risk – the trick is keeping your eye on the ball and...more

DOJ’s Compliance Counsel & Compliance Expectations

The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU,...more

Rubber Soul at 50 and Continued Operationalizing of Your Compliance Program

Last week was the 50th anniversary of one of the seminal Beatles’ albums, Rubber Soul. Even a half-century later, it remains one of the most critically acclaimed LPs in history. As noted in the Wall Street Journal (WSJ)...more

Win-Wins: Looking for Business and Compliance Success

A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success...more

How Can I Make Sure My Compliance Training Program Covers All My Risks?

Building a compliance training program that covers all of your organization’s risks isn’t easy. To do it in a way that ensures you cover your bases without creating training fatigue means creating a multiyear training...more

Australia Implementing Reforms to the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)

As most recently reported in our October 28, 2015, Global Regulatory Update, the Australian government is implementing reforms to the National Industrial Chemicals Notification and Assessment Scheme (NICNAS). According to an...more

Adequate Procedures—The Current State of Play

The legal concept of “adequate procedures” was introduced in the UK Bribery Act in 2010 as a defence to the corporate offence of failing to prevent bribery. That said, the concept itself has in fact been present in corporate...more

Compliance Counsel Metrics-Part I, Board and Senior Management Roles

We begin our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie called for her review of compliance programs. Today we review the first criteria...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

Anti-Corruption: Why Programs Fail

Today, companies around the world face daily challenges associated with corruption. This risk coupled with new laws and heightened enforcement are just a few of the factors driving companies to implement and improve...more

Layla and Other Love Songs and Risk Assessments

On this date in October 1971, Duane Allman died. He was the co-founder, along with his brother Greg, of the Allman Brothers Band. For my money he was one of the greatest guitarists of all time. At the time of his death, the...more

Are You Overcomplicating Your Cybersecurity Processes?

Yes. I just asked that. For many, the response is likely “Yes! Of course we are! It’s *&^%$% cybersecurity – it’s complicated!” To which I would respond “Touché. It is…but it needn’t be overly complicated.” So, of...more

Tips for Going Global: Plan Before You Expand

Companies enjoying success in the U.S. often seek global expansion to gain strategic benefits from accessing new markets—new revenue potential, talent acquisition and increased brand awareness. Before replicating your...more

Building a Due Diligence Infrastructure (Part IV of IV)

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

Fantasy Sports Scandal Shows Importance of E&C Programs for Growing Companies

A recent scandal rocking the daily sports fantasy industry is another example that shows why companies—particularly young, growing companies—need ethics and compliance programs. Without them, it’s a good bet problems will...more

U.S. SEC Proposes Liquidity Risk Management Programs, Optional “Swing Pricing,” and Liquidity Reporting for Mutual Funds and...

On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more

Interview: Amy Much - Director, Global Compliance, Under Armour

Protect This House - Amy Much discusses building a compliance program from the ground up at a fast moving, international organization....more

Dissecting a Bribery Violation: Two Important Questions to Answer

In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more

Meaningful Use Audits: Proactive Tips for Success

For health care professionals who began accepting Meaningful Use incentive money at the outset of availability under the Medicare option in 2011, the year 2015 is an important year. If the provider has met all core...more

New Study Highlights Anti-Bribery & Corruption Gaps & Risks

Everyone reading this post should have conducted a corporate risk assessment (CRA) in the past couple years. If not, stop reading and go conduct one now. Seriously, how can you know if your compliance program resources,...more

Failing to prevent bribery – prevention is better than cure

On 25 September 2015, the Civil Recovery Unit in Scotland recovered £212,800 from Brand-Rex Limited ("Brand-Rex") under an agreed civil settlement, after Brand-Rex self-reported the fact that it had benefited from unlawful...more

Astros in the Playoffs, Will Hell Freeze Over?

When recently I contacted the Underworld about the potential listing of this vast property, I was stunned when Satan himself answered the phone. While I was tempted to ask what happened to all his hired help down there,...more

Making Compliance Easier and Smarter Through Technology: Intuitive Interface and Intelligent Data Gathering is Helping WorldRemit...

WorldRemit is an online money transfer service. It’s bringing a strong challenge to other players in this field through easier-to-use services and lower fees. But while it may be an innovative company, it is still challenged...more

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