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
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
Hotlines are an incredibly valuable tool for identifying compliance issues and many other problems. Every organization should have a system for people to report—either anonymously or with reporter identification....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
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
Don’t look now, but the noisy debate over artificial intelligence (AI) has risen a few notches with the recent introduction of ChatGPT. AI has been a topic of conversation for several years, but ChatGPT has taken everyone’s...more
5/3/2023
/ Artificial Intelligence ,
Automated Systems ,
Bots ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Machine Learning ,
Risk Assessment ,
Risk Management ,
Technology
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
I recently returned from the Corporate Compliance Outreach Event—presented in late September by the Federal Bureau of Investigation (FBI)—a popular event SCCE & HCCA has sponsored with the FBI annually. I last wrote about the...more
Compliance Today - December 2022 -
Having a solid understanding of the challenges our operating units face provides tremendous perspective for the compliance team, enabling it to more fully understand and assist with...more
CEP Magazine - November 2022 -
Inspiration sometimes comes from unexpected places. I like to read books on a variety of topics. In one I read recently, the astrophysicist author described the second law of thermodynamics...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
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
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