As most of you who’ve heard me speak or read my columns know, I’m a strong supporter of using data analytics in compliance programs. It’s an important tool that all compliance professionals should have a working understanding...more
By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Management Systems ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Internal Controls ,
Pilot Programs ,
Reporting Requirements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Civil Monetary Penalty ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Employees ,
Ethics ,
Internal Investigations ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
United Arab Emirates (UAE)
This year’s annual Compliance Institute (CI) provided a strong reminder of just how fortunate we are to have such a strong relationship with the U.S. Department of Health and Human Services Office of Inspector General (OIG)....more
Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more
7/15/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Communications ,
Corporate Culture ,
Corporate Governance ,
Employees ,
Ethics ,
Internal Controls ,
Policies and Procedures ,
Strategic Enforcement Plan ,
Training
Anytime a compliance violation occurs—or even a breakdown in compliance controls that doesn’t ultimately result in noncompliance—the remediation process takes center stage. And this is where questions of how and why are...more
6/4/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Enforcement ,
Healthcare ,
Internal Controls ,
Noncompliance ,
Policies and Procedures ,
Remediation
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
6/4/2024
/ Anti-Bribery ,
Anti-Corruption ,
Best Practices ,
Bribery ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Governance ,
Corruption ,
Ethics ,
Noncompliance ,
OECD ,
Regulatory Requirements ,
Risk Management
As we’ve noted here before, numerous environmental, social, and governance aspects have very clear compliance ramifications, whether in the form of laws and regulations or stakeholder expectations that can result in serious...more
4/26/2024
/ Chief Ethics and Compliance Officers (CECO) ,
Climate Change ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Social Responsibility ,
Environmental Social & Governance (ESG) ,
Ethics ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
Much has been written about the importance of identifying lessons learned and taking remedial action in the aftermath of an investigation into compliance failures. But an equally valuable exercise can result from exploring...more
4/1/2024
/ Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Failure to Comply ,
Internal Controls ,
Internal Investigations ,
Investigations ,
Remedial Actions ,
Risk Assessment ,
Risk Management
Inspiration for this month’s column comes from our local newspaper in the Twin Cities, the StarTribune, in a column by Ross Levin. Levin discusses the psychological distinction between running towards something versus running...more
I recently read about a banker being fired for inflating his expense report to the tune of a sandwich, some pasta, and a coffee. A judge ruled in the bank’s favor in a wrongful dismissal suit filed by the former...more
Inspiration for this month’s column came from a recent article written by Amber MacArthur, who spoke at SCCE’s Compliance & Ethics Institute several years ago. I’ve followed Amber for years, often finding her writing to be...more
Perhaps you haven’t pondered this question. On work-from-home days, do burglars break into their own homes? Or is this time spent doing research, preparing plans, taking online training courses on emerging best practices,...more
10/3/2023
/ Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Ethics ,
Healthcare ,
Healthcare Reform ,
Professional Development ,
Professional Networking ,
Relationship Development ,
Remote Working ,
Research and Development ,
Training
A recent news report reminded me of how difficult it can be to manage compliance and environmental, social, and governance (ESG) risks. You may have seen the report: a tiny capsule the size of a small coin fell out of a truck...more
This month’s column is devoted to the idea of “testing out” of compliance training, a topic I addressed in my opening comments at the Compliance & Ethics Institute in October, but in a clumsy manner. I think I came across as...more
I managed not to lose my temper when a training skeptic informed me that he wasn’t a fan of compliance training because “it’s not going to make a dishonest person do the right thing.” Indeed, I doubt anyone who previously had...more
2/2/2023
/ Best Practices ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Employee Training ,
Employees ,
Ethics ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
Training
CEP Magazine (June 2022) -
One of the best methods of learning about compliance and ethics programs is to review enforcement actions. And some recent actions provide very useful guidance regarding one of the most...more
Environmental, social, and governance (ESG) issues have been around for many years under a variety of different names (e.g., sustainability, etc.). Until recently, ESG was often considered to be a public relations function,...more
There has been much discussion over the years about the relationship between enterprise risk management (ERM) and compliance risk management. Making the discussions more complex has been a tendency to approach risk management...more