Risk Management Compliance

News & Analysis as of

The Real Explanation for the Record Year for FCPA Enforcement

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

Matt Ellis-The FCPA in Latin America

When I received my copy, my first thought was that, finally, it’s about time for this book to come out. Then I read it and realized I was glad he put so much time into it. I am referring to Matt Ellis’ new book The FCPA in...more

Compliance Trends and Predictions for 2017

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

Keep Your (Compliance) Eye on the Road

It is time to give a shout out to one of Houston’s hometown hero’s, the Houston Rockets. Until the Houston Dynamos came along, they were the only professional sports franchise to bring a championship to Houston. They brought...more

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

Once again it’s time for our annual review of trends and events that will impact your Ethics and Compliance (E&C) program in the year ahead. This year presents a unique challenge. We are preparing our predictions...more

Focus On Enabling Your People, Not Controlling Them, To Create an Effective Compliance Culture

When employees of all levels believe in and support policies and standards, that’s when you see real compliance. In-house perspective from NetApp GC, Matt Fawcett....more

The Compliance Oversight Review Committee

This week has evolved into an exploration of different types of compliance committees a company might employ to make their compliance function more effective. On Monday, together with Baker Hughes Incorporated (BHI) Chief...more

Gluten Free Compliance

This past November, I had the pleasure of sitting down with Sean Freidlin, Marketing Manager of Compliance & Ethics at SAI Global, www.saiglobal.com  at The Little Beet Restaurant in NYC, to discuss my history with...more

Forget About a Risk Assessment – Conduct a Risk AND Compliance Program Assessment

A Chief Compliance Officer can get lost in terms, titles, risk management solutions, effective services, magic bullets, absolute requirements and ultimately confusion. Whether the strategy is called lines of defense or some...more

Top 10 Ethics & Compliance Predictions and Recommendations for 2017

2016 was an eventful year in the world of ethics and compliance. We lived and learned through the first year of the Yates Memo; we faced the momentous Brexit and dissected what it would mean for ethics and compliance; we...more

Code of Conduct Training – Now What?

When it comes to corporate compliance programs, change does not occur quickly. CCOs are extremely pleased with their improved delivery of code of conduct training. Across the board, companies are refining their codes of...more

France’s Major Anti-Corruption Reform: What’s Next for Companies and Their Top Management?

Changes to France's anti-bribery system require large companies and their top management to implement an anti-corruption compliance program. After a new examination of the bill by both Chambers of Parliament and the...more

Doing the Two-Step: Prioritizing Risks and Allocating Resources

Chief compliance officers face imposing tasks on a daily basis. The tasks often look insurmountable and it is easy for CCOs to just turn away and find a more manageable set of tasks....more

For the Corporate Compliance Department – Communicate, Communicate, then Communicate

In many ways compliance is about communication. Your role as a Chief Compliance Officer (CCO) or compliance practitioner is to communicate expectations around compliance and responding to questions from the business unit on...more

Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a...more

Coordinating Third Party Due Diligence and Procurement

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

Third-Party Risk Programs Should Focus on Offense, not Defense

Just 43 percent of organizations surveyed in NAVEX Global’s 2016 Ethics & Compliance Third Party Risk Management Report said they evaluated third parties before engaging with them—down from 68 percent in 2015....more

Spikes in Sales and Compliance

What is risk and how should it be evaluated? What is the data that should be reviewed to determine if an increase in sales is based on unethical or even illegal behavior? Finally, what happens when you migrate company...more

The Myths Surrounding Ethics and Compliance Programs

Chief compliance officers have a difficult job. That is a real profound grasp of the obvious. CCOs face an unending onslaught of tasks, risks and juggling of concerns and activities. On many respects, a CCO’s job is never...more

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

When Managing Whistleblower and Retaliation Risk, Tools are Important – Processes and People are Critical

One collection of terms I hear a lot is “tools, processes and people.” All three need to be successfully deployed to make a compliance program run properly while also creating an organizational culture that supports...more

If Things Have to Be Risky for Your Third-Party Risk Management Program to be Valuable, You’re Doing It Wrong.

Seventy-five percent of respondents in the 2016 Ethics & Compliance Third Party Risk Management Benchmark Report rejected at least one third party as a business partner last year because of high risk factors identified in due...more

Due Diligence Basics – Beneficial Ownership

I hate to be the harbinger of bad news; that is against my nature; I am naturally an optimistic person. As I always say, there are solutions to every problem....more

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

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