Compliance Today - November 2022 -
No, not that cancel culture. I’m talking about the new cancel culture, which seems to have emerged concurrently with the pandemic.
When COVID-19 hit hard in early 2020, many...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
CT magazine (October 2022) -
Flying a plane is an incredibly complex job that requires tremendous amounts of training. Yet, when a pilot is suddenly unavailable, the airline usually locates another pilot who is equally...more
CEP Magazine (October 2022) -
A recent case reminded me of how easy it is to use shell companies to perpetrate fraud. A former associate general counsel who handled allegations of employee misconduct for a company created...more
CEP Magazine (September 2022) -
Incentive plans for corporate executives have been linked to financial metrics for many years. Adding environmental, social, and governance (ESG) metrics to these compensation plans is a...more
CT magazine (September 2022) -
Flying a plane is an incredibly complex job that requires tremendous amounts of training. Yet, when a pilot is suddenly unavailable, the airline usually locates another pilot who is equally...more
CEP Magazine (September 2022) -
This month’s column is about something I hope you never have to address: cooperating with government officials in connection with an investigation into a compliance violation at your...more
CEP Magazine (August 2022) -
The Association of Certified Fraud Examiners (ACFE) has been publishing a study on fraud every two years since 1996. This year’s edition, Occupational Fraud 2022: A Report to the Nations, is...more
CT magazine (August 2022) -
I recently read through Occupational Fraud 2022: A Report to the Nations, the biennial study published by the Association of Certified Fraud Examiners (ACFE). I always look forward to this...more
CEP Magazine (June 2022) -
If you’re even remotely new to environmental, social, and governance (ESG) reporting and disclosures, your head might be spinning in your attempt to figure out which set(s) of rules you need to...more
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
CT magazine (July 2022) -
I had planned to devote this month’s column to a discussion of how organizations identify new compliance risks, avoiding the problems associated with simply reassessing the same old risks every...more
CT Magazine (June 2022) -
I recently heard the story of someone who had an interview for a job as a lab technician. And the story reminded me of an important aspect of compliance risk assessments, one that is often...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 – May 2022 -
In January, the U.S. Federal Trade Commission (FTC) published two new guides on marketing issues associated with the use of customer reviews. Put this risk area into the ever-growing bucket of...more
Compliance Today (May 2022) -
Would a law that makes it illegal to mislead the chief compliance officer (CCO) help or hinder the mission of the compliance function? We may find out, albeit on a very limited scale, if one...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
Compliance Today (April 2022) -
“Function creep” is not a term used to describe a person you don’t like. It refers to using a technology for something beyond its original intended use.
The pandemic has changed many...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
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