CISOs, compliance officers, corporate boards, and other senior executives are quick to worry these days about the risks of artificial intelligence – but fear not! Some of the brightest minds in technology have built a tool to...more
9/19/2024
/ Artificial Intelligence ,
Board of Directors ,
Chief Compliance Officers ,
Chief Information Security Officer (CISO) ,
Databases ,
Ethics ,
Governance Standards ,
Liability ,
Machine Learning ,
Noncompliance ,
Risk Management
Compliance officers need to think about fraud and misconduct risks all the time, which means you need to talk to others in your organization about exactly how those risks might happen – but what’s the right way for you to do...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
8/9/2024
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Internal Reporting ,
IRS ,
Regulatory Agencies ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers
Ethics and compliance officers have long had an uneasy relationship with corporate sustainability efforts, mostly because most compliance officers aren’t quite sure they want – or know how to handle – responsibility for it. ...more
7/11/2024
/ Carbon Emissions ,
Contract Management ,
Cybersecurity ,
Environmental Social & Governance (ESG) ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Modern Slavery Act ,
Policies and Procedures ,
Popular ,
Risk Management ,
Supply Chain ,
Sustainability
At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more
7/3/2024
/ Anti-Corruption ,
Anti-Kickback Statute ,
Bribery ,
Chevron Deference ,
Civil Monetary Penalty ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Snyder v United States
Corporate compliance officers have been bracing for regulation of how companies can use artificial intelligence in their daily business operations. Now we have a fresh glimpse of what that regulatory landscape might look like...more
Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more
5/29/2024
/ Anti-Corruption ,
Compliance ,
Contract Management ,
Corruption ,
Distributors ,
Due Diligence ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Recordkeeping Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Technology Sector ,
Third-Party
The U.S. Federal Trade Commission sent shockwaves through the corporate world in April when the agency imposed a ban on noncompete agreements – and like any good shockwave, this new rule will reverberate through the ethics...more
Explaining how a strong culture of ethics and compliance can help your enterprise to succeed is tricky business. So imagine my delight when I came across a recent speech from a banking regulator who did exactly that....more
Corporations have struggled to manage cybersecurity risk for years, and now they have a new tool to help them bring order to chaos: a new and improved cybersecurity risk management framework, released at the end of February...more
The U.S. Supreme Court recently gave whistleblowers an easier path to win retaliation lawsuits they file, making the always delicate task of handling corporate whistleblowers that much more delicate. Compliance and HR teams...more
The rise of artificial intelligence – and specifically of generative AI, which can create entirely new images, sounds, and text with just a few prompts – was the most important technology development of this decade. The...more
Risk assessments are one of the most important tasks a compliance officer performs – and also one of the most confounding. How do you keep assessing your organization’s risks in a disciplined, methodical manner, when the...more
One year ago, compliance officers began 2023 dazzled by the potential of artificial intelligence, and braced for new regulations to govern how corporate organizations use AI. Then a funny thing happened: governments didn’t...more
The U.S. Securities and Exchange Commission recently announced that its long-awaited greenhouse gas disclosure rule will be delayed yet again, most likely until April 2024. This raises an important question for compliance and...more
12/29/2023
/ Audits ,
Climate Change ,
Compliance ,
Data Collection ,
Environmental Social & Governance (ESG) ,
Greenhouse Gas Emissions ,
Proposed Rules ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Third-Party
For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
12/8/2023
/ Board of Directors ,
CCO ,
CEOs ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Healthcare ,
Healthcare Reform ,
OIG ,
Risk Mitigation
In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more
11/30/2023
/ Acquisitions ,
Bribery ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Mergers ,
Penalties ,
Popular ,
Price-Fixing ,
Sanction Violations
Everyone even peripherally involved with corporate governance, compliance, or risk management knows that corporate boards need more CISOs to help them navigate today’s cyber-saturated world. Even better, plenty of CISOs are...more
For the last several weeks I have been working with NAVEX to research whistleblower protection laws across Europe. Meanwhile, several benchmarking surveys about corporate compliance programs have arrived lately, with some...more
Don’t faint from surprise at this news, but corporate compliance is a world with lots of lingo that can be difficult to understand. Case in point: a “policy about policies” – something that sounds obscure, but actually is one...more
Compliance and technology executives, we need to talk. Or, more accurately, you need to talk more often – to each other.
In the last 18 months, the Securities and Exchange Commission sanctioned three companies for making...more
As compliance officers enter 2023, they need to learn how to handle a double-edged sword: the Justice Department’s new requirement that as part of corporate misconduct resolutions, CCOs must certify the effectiveness of their...more
ChatGPT really is a marvelous technology – an artificial intelligence designed to answer just about any question a person might ask it – and yet, somehow, it leaves CISOs and compliance officers with even more questions....more
Workplace cultures that prioritize learning and consistently strive to eliminate harassment and retaliation do not happen overnight. It takes continuous and proactive effort to ensure employees feel safe and respected....more
Corporate compliance officers grapple all the time with what their companies should do to develop effective information protection programs. Thankfully the Federal Trade Commission has given us two recent enforcement actions...more