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Risk Assessments-the Cornerstone of Your Compliance Program, Part II

One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different approaches in his article “Practical Suggestions for Conducting Risk...more

Risk Assessments-the Cornerstone of Your Compliance Program, Part I

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999, in the Metcalf & Eddy enforcement action, the US Department of Justice (DOJ) has said that risk assessments...more

FCPA Compliance Programs A Review of Best Practices [Video]

In response to aggressive FCPA enforcement, the compliance industry has embraced innovative strategies and tools. Whether your company is large, medium or small, it is important to stay abreast of industry best practices....more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Continuous Improvement Of Your Compliance Program, Part II

Anti-corruption, anti-bribery, anti-money laundering (AML) programs policies and procedures and even export control systems are seemingly in a constant state of evolution. Many companies are struggling with the challenge of...more

Tailor Your Antitrust Training To Effectively Combat Risk

When we think about compliance training, we typically conjure up the popular topics: sexual harassment training, anti-bribery training, code of ethics training…the superstars, the popular kids. The courses that most employees...more

Global Boardroom Risk Solutions Newsletter

Now more than ever, there is a need for risk solutions in the boardroom. Any organization can be faced with a significant crisis, whether a fraud investigation, a regulatory infringement, allegations of anticompetitive...more

Boards of Directors Charged with Cybersecurity Risk Management by SEC Commissioner

Last week, SEC Commissioner Luis Aguilar outlined expectations for directors of public companies to manage cybersecurity risk. If you think it is enough that a board of directors reviews annual budgets for privacy and IT...more

Meaningful Compliance Equals Sound Financial Management

In traditional finance parlance the term "risk management" involves identifying events that can have adverse financial consequences and then taking action to prevent and/or minimize the damage caused by these events. Thus...more

Employee Handbooks & Progressive Discipline Policies

1. Introduction. Under the “risk management” approach to human resources management, an employer should set the standards for its policies and practices at a level that it is certain it will enforce uniformly...more

SEC Requires Greater Disclosure of Cyber Events

Cyber is still a relatively young risk and the various stakeholders in cyber-risk are at times, still trying to determine their particular role. This includes the officers and/or directors of companies for establishing...more

Three Practical Steps to Managing FCPA & Anti-Corruption Risks

Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively...more

The Mann Gulch Fire and How Far Down the Chain Do You Need to Go?

Robert Sallee died last week. A smoke jumper, he was the last survivor of the Mann Gulch Fire, one of the worst disasters in the history of the US Forest Service. Sallee’s story and that of the Mann Gulch Fire was detailed in...more

Look Beyond Hotline Calls and Business Ethics Training Scores for Ethics and Compliance Metrics That Give Real Insight

I came across a great blog this week by Jim Nortz, a compliance and ethics consultant and educator, titled Business Ethics: 3 Questions Every Business Leader Must Ask. If you follow my blogs, you won’t be surprised that I...more

Making the Most of Compliance and Ethics Week

This week, ethics and compliance departments at organizations across the country will celebrate Corporate Ethics and Compliance Week, an opportunity to highlight the essential connection between business integrity and ethics....more

Gehrig’s Streak Ends And Compliance Week 2014 Is Near

Today we celebrate greatness in two areas. The first is in baseball as on this day in 1939, “New York Yankees first baseman Lou Gehrig benches himself for poor play ending his streak of consecutive games played at 2,130....more

Attention SharePoint Users! SharePoint Is NOT a Solid Compliance Management System

In part 2 of our blog series, we’re going to focus on the use of SharePoint as a compliance management system. Capturing attestations and certifications on policies is an important part of the compliance program and delivers...more

Mitigating Bribery Risks With Financial Controls

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

Survey Finds Money Laundering Becoming a Top Priority for Management

Financial institutions are making significant adjustments in their approach to anti-money laundering (AML) compliance issues in the face of escalating global regulatory enforcement. According to KPMG’s 2014 AML Survey, 88% of...more

Keeping Compliance Focus On Risky Interactions

People who consistently miss the point are frustrating. Focus is an important discipline. Whatever you do in life, the ability to focus is critical....more

Alfred The Great, GE And The Management Of Third Party Risk

I am currently studying Medieval England including the reign of Alfred the Great. As you might expect with someone monikered as ‘The Great’ he is certainly considered right up there with the greatest Kings of England. Not...more

Board-Level Risk Management – Bridging the Gap

The pendulum of board-level risk management has shifted. For many public companies, intentional risk management has evolved in recent years from virtually nonexistent to finance department driven (focusing on internal...more

FINRA Conducting Cyber-Security Sweep Exam

Reacting in part to recent data-breaches and cyber-attacks on larger retailers, the Financial Industry Regulatory Authority (“FINRA”) is conducting a targeted examination of some 20 broker-dealer member firms’ compliance and...more

SEC Staff Offers Roadmap for Alternative Investment Due Diligence Processes

The SEC believes that investment advisers, including pension consultants, are increasingly recommending that their clients invest a portion of their portfolios in private alternative investment funds. In light of that trend,...more

More Lessons From Workplace Safety For The Compliance Practitioner

I have long believed that the compliance discipline has quite a bit to learn from the area of safety in the workplace. This is not only because I believe that the changes in corporate attitudes about safety presage many of...more

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