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
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
A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more
4/26/2024
/ Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Disclosure ,
Ethics ,
Internal Controls ,
Internal Investigations ,
Risk Management ,
Self-Reporting
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
On July 31, the European Commission adopted the first set of rules under the European Sustainability Reporting Standards (ESRS). The ESRS is an important follow-up to the adoption of the Corporate Sustainability Reporting...more
11/6/2023
/ Compliance ,
Corporate Governance ,
Disclosure ,
Environmental Social & Governance (ESG) ,
EU ,
European Commission ,
Internal Controls ,
New Rules ,
Policies and Procedures ,
Regulatory Standards ,
Reporting Requirements ,
Sustainable Business Practices
Two stories in the news recently caught my eye. In the first, a janitor allegedly shut off the power to a freezer after hearing “annoying alarms.” He ended up ruining decades of research. In the other story, an American...more
The Wall Street Journal recently reported that the CEO of Uber spent time driving for the company under an assumed name. He filled out the forms like any prospective driver and drove around customers....more
CT magazine (October 2022) -
Last month, I wrote about succession planning in the compliance department, an important concept we should always consider to avoid a big gap when the chief compliance officer, or anyone else...more
CEP Magazine (June 2022) -
Most compliance professionals use some variation of the same model for assessing the severity of a compliance risk as part of a periodic risk assessment. Severity often considers the likelihood...more
CEP Magazine – April 2022 -
As usual, Joe Murphy wrote an excellent column this month dealing with risk assessments. We must be leading parallel lives, because I also had an idea about risk assessments I wanted to share....more
CEP Magazine (March 2022) -
In November 2021, the Organisation for Economic Co-operation and Development (OECD) issued a significant update to its guidance on combating bribery of foreign public officials, replacing its...more
3/11/2022
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corruption ,
Due Diligence ,
Internal Controls ,
OECD ,
Risk Assessment ,
Risk Mitigation ,
Suppliers ,
Supply Chain
Compliance Today (March 2022) -
Early in the pandemic, when employees not directly involved in patient care were sent home, much was said about the importance of making modifications to internal controls in connection...more