News & Analysis as of

Risk Management Compliance

Operationalizing Compliance: Part II – Breaking Through Obstacles

by Thomas Fox on

This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am...more

The Astros, Regression to the Mean and Compliance

by Thomas Fox on

Being a Houston baseball fan has been largely pain, misery and suffering. While we have not gone 80+ years or even a century without winning a World Series it is not for lack of ineptitude. It is because the Houston Major...more

From Dr. No to an Agile Compliance Program

by Thomas Fox on

How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more

The State of Mind of a White Collar Criminal

by Michael Volkov on

As a chief compliance officer, it is important to consider the mindset of a criminal. Not to complete tasks and accomplish your objectives. Instead, it is important to understand the criminal mind, what makes them tick and...more

AI and Compliance Going Forward: Welcome to ComTech

by Thomas Fox on

What will be the role of Artificial Intelligence (AI) in compliance going forward? In Wednesday’s Compliance into the Weeds podcast, Matt Kelly and I continue our discussion, that we began several years ago, of how technology...more

Data Privacy and Security – What is the Difference?

by Michael Volkov on

The terms “Data Privacy and Security” are being thrown around a lot lately. Just recently, England’s health services and medical facilities were shut-down and the target of a ransom note (demanding, of course, payment in...more

Managing Sanctions and Export Control Risks in the Health Care Industry

by Ropes & Gray LLP on

Over the past 15 years, pharmaceutical manufacturers, medical device companies, and other participants in the health care industry have been regular targets of U.S. Foreign Corrupt Practices Act (“FCPA”) enforcement actions...more

Setting Your Compliance Program by the North Star

by Thomas Fox on

Today I celebrate a potpourri of history to lead into some leadership lesson for a Chief Compliance Officer (CCO) or aspiring CCO. According to This Day In History, today marks the second formation of the Committees of...more

To Learn About Your Business, Get Out into the Field

by Thomas Fox on

I have not written too much about the City of Houston hometown heroes, those intrepid Houston Astros, this season. One reason is that the bumbling owner has finally learned to stop making some of the inane pronouncements he...more

The Trump Administration: The Business Impact

by Thomas Fox on

If we do not speak up, there may not be an opportunity later. ...more

Corporate Shell Games and KYC Requirements

by Michael Volkov on

Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more

10 Questions to Operationalizing Compliance

by Thomas Fox on

A Harvard Business Review (HBR) article, entitled “Does Management Really Work?” by Nicholas Bloom, Raffaella Sadun and John Van Reenen, provided some succinct advice about what a business can do to improve its management...more

Star Wars and the Use of Video Communications in a Best Practices Compliance Program

by Thomas Fox on

May 4th is universally recognized (at least in the universe I inhabit) as Star Wars Day. According to Wikipedia, “May 4 is called Star Wars Day because of the popularity of a common pun spoken on this day. Since the phrase...more

Farewell to Racehorse and Welcome to Project Success

by Thomas Fox on

Every trial lawyer in Texas has heard of him, a legendary trial lawyer with a legendary name, Richard ‘Racehorse’ Haynes; who died over the weekend at the age of 90. He took up the mantel of great Houston criminal defense...more

Knowing Your Employees and Incident Management Systems

by Michael Volkov on

Chief compliance officers know the importance of trust, not just as a foundation of a global company’s compliance program, but in the context of knowing what company employees are doing out in the field. CCOs will always say...more

AI for Risk Management in Compliance – A New Business Advantage

by Thomas Fox on

There have been some articles recently which discussed the revolution of technology into compliance, specifically with the introduction of Artificial Intelligence (AI) into the profession. A few pieces claimed this was...more

Dealing with Violations in Export and Import Transactions

by Williams Mullen on

You are the general counsel or CEO of your company. Your compliance manager comes into your office and tells you that he/she may have discovered an export violation within the company. Or perhaps you have received a directed...more

What Compliance Needs to Know About Data Privacy and Security

by Michael Volkov on

You don’t have to be a tech-savvy computer genius to address the basics of data privacy. Like many areas which compliance departments oversee, asking the right question and getting the right internal controls in place are the...more

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Suggested Questions for the Compliance Officer

by Ruder Ware on

In a previous blog post, I promised to release a list of questions a Board of Directors (Board) might ask its compliance officer. This post is intended to fulfill that promise. My intent is to help Board members exercise...more

The Risk Management Process in Compliance

by Thomas Fox on

An exploration of risk forecasting, risk assessment and risk-based monitoring for the compliance profession. ...more

Long-Running Corruption Scheme Exposed in Brazil: Operation "Exposed Invoice" Provides Continuous Improvement Opportunity for...

by Pepper Hamilton LLP on

A massive scheme involving medical products sales to Brazilian public entities has led to recent high-profile arrests. The events highlight the importance to a well-functioning compliance program of keeping up with new...more

"Cybersecurity Trends for Boards of Directors"

Cybersecurity has in recent years become an integral component of a board’s role in risk oversight, but directors often find themselves in unfamiliar territory when it comes to formulating policies and oversight processes...more

The Axe Falls on Wells Fargo – A Scathing Independent Report (Part II of III)

by Michael Volkov on

In a scathing report, the independent directors at Wells Fargo released their findings and actions based on a comprehensive internal investigation of Wells Fargo’s sales abuses. Based on its findings, Wells Fargo’s...more

[Webinar] FCPA Violations – Only a Risk For Big Companies? - April 25th, 1:00pm CST

by Robins Kaplan LLP on

Tuesday, April 25, 2017, 1:00 P.M. CST -- In November, J.P. Morgan paid $264 million to resolve FCPA offenses related to its “Sons and Daughters Program.” Could a small, entrepreneurial company find themselves in similar...more

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