Risk Management Compliance

News & Analysis as of

Teaching the Board How to Oversee and Monitor the Compliance Function

I have never let my schooling interfere with my education – Mark Twain (unverified). Everything has its limit–iron ore cannot be educated into gold. – Mark Twain (verified) Board members believe they know what they...more

[Webinar] FCPA Spotlight: Best Practices for Controls and Records - May 20th, 1:00pm EDT

In this era of increased attention to corruption, the U.S. Justice Department and Securities and Exchange Commission are increasingly using the FCPA's books and records and internal controls provisions to prosecute improper...more

The Pen is Mightier than the Compliance Sword

Nicole Rose brings a breath of fresh air to compliance. 6 years ago she swapped her legal practicing certificate for her pen and has been thriving ever since. She founded Create Training almost 3 years ago, and over this...more

CIO Insights into Compliance’s Use of Data Analysis

Earlier this year the Wall Street Journal (WSJ) ran a series called Journal Report entitled CIO Network. They met with and surveyed many Chief Information Officers (CIOs) over multiple business sectors. I found the entire...more

Panama Papers Scandal Puts Third Party Risk in Focus

The Panama Papers scandal should serve as a wake-up call for every organization—and it should prompt compliance officers to closely scrutinize the third party vendors they do business with. ...more

Panel Offers Insights on Doing Business in Colombia

As Colombia moves toward a peace agreement with FARC rebels and works to accomplish reforms necessary for OECD accession, the nation stands poised at the threshold of significant growth and transformation. Such was the...more

Tribute to Dr. Jannetta and Improvisation in Compliance

It is rare you are able to write about someone who directly changed the quality of your life. Rarer yet that you did not know about him, only what he created, until you read his obituary. That happened to me recently when I...more

Managing Risk: Integrating CSR and Compliance Functions Effectively

Corporate social responsibility (“CSR”) is an important component of overall enterprise risk management for many companies. That said, too often, corporate implementation of CSR commitments is reliant upon diverse functions...more

FINRA Targets AML Programs and “Culture of Compliance” as 2016 Enforcement Priority, Particularly for High-Risk Broker/Dealers

Under Securities and Exchange Commission (“SEC”) authorization, the Financial Industry Regulatory Authority (“FINRA”) is “responsible for regulating (1) all securities firms that do business with the public[,]” (2) key stock...more

Compliance 2.0: DOJ Pushes the Compliance Agenda

The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex...more

Checking In on “The Year of Third-Party Due Diligence”

Hui Chen, the Department of Justice’s Compliance Counsel, recently stated that 2015 was the year of due diligence and third-party compliance. A recent survey conducted by Kroll and Ethisphere provided a status check on how...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

The Banking Stepchild: Money Service Businesses

Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not...more

Prog Rock Week – Part III: Watcher of the Skies and Staying Sane as the CCO

As noted by Dan Epstein, in the Rolling Stone article “50 Greatest Prog Rock Albums of All Time”, the Genesis album Foxtrot was arguably the band’s first great album. The album “took the eccentric worldview and symphonic...more

OCC Revises CMP Policy

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

Prog Rock Week – Part II: Karn Evil 9 and Kaizen for Compliance

Yesterday, I began Prog Rock Week with a tribute to Keith Emerson. So sit back my friends and enjoy the show that never ends, as I explore my favorite prog rock albums and cuts. Today, I will further honor Emerson and his...more

Top Ten Ethics & Compliance Predictions & Recommendations for 2016

To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more

[Event] Tech Talk: Managing an Effective Whistleblower Hotline - March 15th, 12:00 p.m., London

These days, an effective whistleblower hotline represents a crucial element of any public or private organisation’s Governance, Risk and Compliance (GRC) programme. Indeed, it is often one of the first compliance initiatives...more

2015 Ethics & Compliance Third Party Risk Management Benchmark Report

Organizations are still coming to terms with the breadth and depth of their third party risk. An effective third party risk management program is in the interest of all organization —regardless of their size, industry, and...more

2016 Trends #9: Cynicism, Fatigue and Compliance Pushback—A Problem We Can No Longer Ignore

You may have already seen the signs of employee cynicism, fatigue or compliance pushback at your organization. Its presence is often indicated by little things. Over the years, some of these signs have become so common we’ve...more

“Tell Us About Your Culture” – FINRA Commences Sweep

In its January 2016 annual exam priorities letter, FINRA announced that it would examine the “compliance culture” at member firms. In furtherance of that goal, in February 2016, FINRA issued a “sweep letter” to members...more

2016 Trends #8: Getting Serious About Anti-Bribery & Corruption Efforts and Third-Party Risk Management

By now, most organizations understand the importance of identifying and addressing any exposure they have to violations of anti-corruption and bribery (ABC) laws. Much attention has been given to recent cases, and to...more

Three Keys to Minimizing Employment Litigation Risks

In this era of shooting-from-the-hip or bombastic Donald Trump comments, companies have to attend to reducing employment litigation risks. In this era of nuisance litigation and employment-focused litigation, companies need...more

Trust as a Fig-Leaf of Poor Compliance and Management

Trust is an important, nurturing presence in the workplace. There is a level of trust inherent in all controls, and NGOs are often dependent on trust, especially in emergency operations, distant field offices, and when...more

Reflections on the SEC- FCPA Enforcement Action Against SAP

The Foreign Corrupt Practices Act (FCPA) enforcement journey, which began last summer with the guilty plea of Vicente Garcia for the payment of bribes to obtain contracts in Panama for his employer, SAP International, ended...more

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