Risk Management Compliance

News & Analysis as of

Building Trust in an Organization as a Step to Operationalizing Compliance

Earlier this week I explored LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report). One of the key findings of the Report was that if there was greater employee trust, the values of ethics...more

Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV)

We all know that a compliance program without business buy-in is, by definition, an ineffective compliance program. The level of business support ranges from “mouthing” support to full-fledged embrace and ownership of...more

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may...more

Deep Dive Due Diligence: Part V – Level III Due Diligence as a Board Tool

Today, I conclude my exploration of Level III, deep dive due diligence, by discussing how a this should be considered as a best practices tool by a Board of Directors in a broader sense. I am joined in this exploration by...more

Deep Dive Due Diligence: Part IV – Level III Due Diligence for 3rd Parties

Today, I continue my exploration of Level III, deep dive due diligence, by discussing how this should be considered for third parties. I am joined this week by Candice Tal, founder and Chief Executive Officer (CEO) of...more

Managing Compliance Risk in the Enterprise

Picture these scenarios: Co-workers email each other about their secret competitive new business. A product manager who was passed over for a promotion exposes his company’s engineering plan on a social media site. An...more

Managing Your Ethical Culture: Measure, Intervene and Remediate

In the wake of ever-constant business scandals (e.g. ZTE, VW, Takata, Odebrecht), chief compliance officers have to refresh their approach and strategy. Everyone agrees, or at least I think they should agree, that a company’s...more

The DOJ Expects “Third-Party Management” from Compliance Programs

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

Deep Dive Due Diligence: Part II – Why Level III Due Diligence for Senior Execs?

Today, I continue my exploration of Level III, deep dive due diligence by considering why you need this type of background investigation in the context of the hiring and promotion of senior managers in an organization. I am...more

Deep Dive Due Diligence: Part I – What is Level III Due Diligence?

There are many levels of due diligence investigation. In a multi-part series this week, I am going to focus on Level III, deep dive due diligence. I am joined in this exploration by Candice Tal, founder and Chief Executive...more

Three Findings Surface in the 2017 EMEA & APAC Culture & Compliance Programme Benchmark Report

The business case for corporate culture and its effects on reputational risk management, regulatory violation and misconduct avoidance has become increasingly tangible over the recent years, and even months. This makes any...more

Creation of Roundabout and Operationalization of Compliance

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

Operationalizing Compliance – How to Reframe the Issue

One of the biggest requirements for a Chief Compliance Officer (CCO) or compliance practitioner is to be a problem solver. Most of us are asked to help solve problems on an almost continuous basis. This leads to one failing...more

IAICM Shine a Light on Corporate Monitors

Any organization is usually the sum of its members. However, to begin a non-profit usually takes not only the vision of one person but quite a bit of work as well. Since 2015, the vision and work of John Hanson, aka The Fraud...more

Day 6 of One Month to Operationalizing Your Compliance Program-Risk Assessments [Video]

The DOJ Evaluation of Corporate Compliance Programs states: • Risk Management Process – What methodology has the company used to identify, analyze, and address the particular risks it faced? • Information Gathering and...more

Pitfalls of Using Big Data Alone

I often write about the use of big data in a best practices compliance program. However, care must be taken in the use and interpretation of big data. One of the clearest reads into this topic is the recent book by Cathy...more

Review, Revise and Re-Organize Your Company’s Internal Controls (Part II of II)

Assuming you made it through Part I of this two-part posting about internal controls, we need to consider a new approach to the design and implementation of internal controls....more

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs in Federal Fraud Investigations

On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more

How to Measure Third-Party Risk Management ROI

One area that has bedeviled Chief Compliance Officers (CCOs) and compliance practitioners is how to determine the return on investment (ROI) for your compliance program regarding the management of third parties. While it is...more

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)

DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training - In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s...more

DOJ’s Compliance Program Evaluation: Risk Assessment, Policies and Procedures and Third-Party Risk Management (Part III of IV)

To design and implement an effective ethics and compliance program, companies have to conduct a risk assessment and tailor its policies and programs to its risk profile. DOJ’s Compliance Evaluation reinforces this framework...more

Horse-trading Your Way to a Better Compliance Program

On this day in 1836, Colonel William Barrett Travis issued his now famous call for help on behalf of the Texan troops defending the Alamo. It has gone down as one of the great cries for freedom-loving peoples everywhere. The...more

7 tips for combating white-collar crime

White-collar crime costs the South African economy a huge amount every year. One expert puts the figure at R930 million a year, and poor conviction rates are estimated to be driving a 50 per cent rise in this kind of crime....more

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

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