News & Analysis as of

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

The Federalist Papers And A Federated Approach To GRC

Today we celebrate one of America’s greatest political commentaries, The Federalist Papers. They were penned by James Madison, Alexander Hamilton and John Jay. They presented their three views on why the Federal Constitution...more

OCC Releases Guidelines on 'Heightened Expectations' for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) recently released proposed amendments to its Part 30 regulations, which reflect the agency's "heightened expectations" for large banks. That release, styled as an "Interim...more

2014 Litigation Report: Managing Risk

In This Issue: Introduction; Food and Beverage Products: Managing Mounting Litigation Risk in the Food and Beverage Industry; Procurement Pitfalls: Best Practices to Manage Risk; Securities and Consumer Class Actions:...more

Federal Reserve Board Seeks Comment On Designated Utilities’ Risk Management Standards, Payment System Risk Policy

On January 10, the Federal Reserve Board proposed revisions to the Regulation HH risk-management standards for certain financial market utilities that have been designated as systemically important by the Financial Stability...more

Queen Victoria And Preparing For Your Risk Assessment

On this day in 1901, Queen Victoria died, ending an era in which most of her British subjects know of no other monarch. She was born in 1819 and came to the throne after the death of her uncle, King William IV, in 1837....more

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