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
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
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
I’m not talking about your organization. I’m talking about that company in your vendor master files. A recent report from Moody’s found some downright silly attributes about shell companies. One that jumped out at me was the...more
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
Much is made of the need for accurate reporting in accordance with recognized standards. But this month, I’m returning to a topic I briefly touched on in July 2023, when I discussed the potential for misleading images and...more
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
I can’t think of a better example of the convergence of environmental, social, and governance (ESG) factors, compliance, and ethics than in marketing and public relations. This area is filled with opportunities and risks...more
7/13/2023
/ Business Strategies ,
Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Diversity and Inclusion Standards (D&I) ,
Environmental Social & Governance (ESG) ,
Ethics ,
Federal Trade Commission (FTC) ,
Greenwashing ,
Marketing ,
Public Communications ,
Public Relations ,
Reporting Requirements ,
Risk Management ,
Shareholders
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
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
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 (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
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
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
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