News & Analysis as of

Risk Management Compliance

No More Excuses: CCOs Have to Embrace Technology

by Michael Volkov on

It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more

Farewell to a Repo Man and Using Laconic Persuasion as a CCO

by Thomas Fox on

The life of a Repo Man is always intense… That was one of the greatest lines from one of the greatest movies from one of the greatest laconic actors of all time. Of course it was Harry Dean Stanton who died over the...more

When is the Right Time? The Indians Streak and Monitoring

by Thomas Fox on

My challenge on when to write about the Indians winning streak informs today’s blog post, as I consider when you should use ongoing monitoring. Every compliance practitioner recognizes the prevent, find and fix tripartite...more

The COSO ERM Framework

by Thomas Fox on

The COSO Enterprise Risk Management (ERM) Framework was released last week. It provides an excellent structure for compliance practitioners and businesses to think through the entire lifecycle of risk management....more

Will Your Assets Be Stranded? The Risk Management Process in ESG and Compliance

by Thomas Fox on

State Street Global Advisors (SSGA) is a company which engages in US and broader international institutional investing, largely on behalf of its clients. Some of the areas it focuses on include environmental, sustainability...more

Compliance Missed Opportunities: CCOs and HR

by Michael Volkov on

A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.”...more

Midnight Cruising with Steely Dan – Finding Patterns in Raked Leaves

by Thomas Fox on

Last Friday on September 1, I began a new installment of my year-long podcast series, where each month I focus on a different compliance topic. This month, I am focusing on innovation in compliance....more

Practicing Compliance

by Thomas Fox on

It has certainly been a week for the ages in Houston, most of Texas and all along the Gulf Coast as Hurricane Harvey has wrecked a level of havoc not scene in that large a swath for many a moon, if ever. Ending this...more

Holmes, the Fog of London and Root Cause Analysis

by Thomas Fox on

My heart and thoughts continue to go out to my fellow Houstonians, fellow Texans and now Louisianans and all other affected by Hurricane Harvey. I continue my exploration of weather related themes from which the compliance...more

Financial Controls and Contract Management Systems

by Michael Volkov on

Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the...more

How the Storms of “The Scottish Play” Inform Your Compliance Program

by Thomas Fox on

In honor of fellow Houstonians, fellow Texans and now our neighbors to the east in Louisiana, who have been impacted by Hurricane Harvey, I continue my weather themed week by considering how Shakespeare used weather as a...more

Challenges in Transitioning from the Law to Compliance

by Michael Volkov on

The legal profession is undergoing significant changes. With an over-supply of attorneys and lower profits, lawyers are looking for new angles to distinguish themselves in the marketplace....more

How Weather Can Bring Analytical Clarity to Compliance

by Thomas Fox on

Sometimes I pick a topic for a week’s theme of blog posts, as I did last week with the topic of soft skills needed to navigate a successful remediation. Then there are times where it appears the theme picks me or at least...more

Ethics, Temptation and Money

by Michael Volkov on

A corporate entity is like its own community – it has a culture, a set of values and principles that form the foundation for the company’s operations, and an overall purpose. The interesting factor that has to be identified,...more

Hurricane Harvey – Reflections on Being Prepared

by Thomas Fox on

We are now half way (hopefully) through what is predicted to be the largest amount of rain seen in one week by the city of Houston and its surrounding environs in the city’s recorded history. First and foremost, my deepest...more

Across the Board-Episode 5, Visualization of Data for a Board

by Thomas Fox on

In this episode, I visit with Joe Oringel, co-founder of Visual Risk IQ, a data-analytics and visualization company. They have developed a manner to not only extract data but present it in a way that is very interesting, very...more

Adolescent Companies Need Ethics & Compliance to Manage Growing Pains

by NAVEX Global on

So what kinds of planning and alignment help corporate ethics programs the most, before expansion phases spin out of control? If the business where you work is smart and lucky, eventually it will hit an expansion phase. This...more

Soft Skills in Remediation: Part III – Communications with Stakeholders

by Thomas Fox on

Today I continue a five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation....more

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

by Thomas Fox on

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

Soft Skills in Remediation: Part II – Project Timing

by Thomas Fox on

Today, I continue a five-part series on what a Chief Compliance Officer (CCO) needs to consider when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I am...more

Soft Skills in Remediation: Part I – The Gatekeepers

by Thomas Fox on

Many Chief Compliance Officers (CCOs) came to the position from the legal department, internal audit or another professional discipline. These professions are technically focused and their training provides little to no soft...more

Day 15 of One Month to More Effective Continuous Improvement-Risk Based Monitoring for Continuous Improvement

by Thomas Fox on

Another mechanism for continuous improvement of your compliance program is through risk-based monitoring. Under Prong 5 of the DOJ’s Evaluation of Corporate Compliance Programs, is the following topic and question: Manifested...more

Why Wells Fargo Needs Compliance Expertise on its Board

by Thomas Fox on

In a New York Times (NYT) Dealb%k article, entitled “Wells Fargo Vice Chairwoman to Succeed Departing Chairman”, Stacy Cowley reported that the Wells Fargo Board of Directors Chairperson, Stephen W. Sanger, will retire at the...more

Leadership Lessons from James Madison

by Thomas Fox on

I continue my leadership series based upon the lives of US Presidents by looking at leadership lessons from the fourth President, James Madison. Madison lived a life full enough for several people. He served as both a member...more

Retaining a “Risky” Third-Party

by Michael Volkov on

Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or...more

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