The issue was a professional debate over the reporting relationship between the chief compliance officer (CCO) and the chief legal officer (CLO)/general counsel. After 20 years of debate, CCOs managed to sway the professional...more
Compliance lessons are life lessons. Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal. Compliance professionals live in the shadow of...more
NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more
NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more
7/19/2024
/ Acquisitions ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Corporate Governance ,
Employee Training ,
Environmental Social & Governance (ESG) ,
Ethics ,
Mergers ,
Risk Management ,
Voluntary Disclosure
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more
Third-party relationships supporting core operations are now more important than ever for most organizations. Yet too often, procurement, information security, compliance, and other professionals are overburdened with the...more
Third-party relationships supporting core operations are now more important than ever for most organizations. Yet too often, procurement, information security, compliance, and other professionals are overburdened with the...more
Chief Compliance Officers are truth-tellers. It comes with the territory. Each and every CCO knows whether its internal investigation program is effective or not. There is not a lot of grey in this area – CCOs know what an...more
Corporate leaders know what to say and when to say it – for example, a CEO may state at an employee meeting, “We want to hear your concerns. We want you to bring these concerns forward and we will address them. We are...more
I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle up without...more
The famous swashbuckling adventure of The Three Musketeers should inspire chief compliance officers to pursue an important concept – the need for teamwork and collaboration is imperative for all compliance programs. We all...more
Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone. To the contrary, as the business adapts through growth, innovation or in response to outside market and...more
The Justice Department’s recent emphasis on ethics and compliance culture, along with greater specificity on “consequence management” is a welcome breath of fresh air. It is a policy coming for a long time and will bring...more
Just when we thought the ethics and compliance landscape was “stable,” the Justice Department pulled the compliance profession further and announced heightened expectations for corporate compliance programs. For...more
It is easy to be dogmatic in blog postings — to express an unvarnished opinion that sounds valid. While it may not be supported by hard data or valid evidence, compliance officers are used to trusting their “gut feelings,”...more
This is a topic that every compliance professional has to address in one form or another. Chief compliance officers are so busy that they often cannot even take the time to tackle this difficult issue. This is a real...more
Compliance professionals are used to internal struggles for influence and resources. Chief compliance officers have devoted years and years to justifying the need to elevate and empower the compliance function. For years,...more
For some reason, many companies do not include Ethics in the title of the CCO but expect the CCO to assume responsibility for a company’s ethical culture. Well, it is high time for companies to confirm this important...more
Chief compliance officers are visionaries. They define a vision with multiple objectives and then they execute on that vision. At all times, CCOs have to maintain that vision and adjust as circumstances change. By...more
Chief compliance officers have a lot of issues to balance on their plate. Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more
As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance...more
As Supreme Court Justice Potter Stewart eloquently opined in Jacobellis v. Ohio (1964), on the legal definition of obscenity, “I know it when I see it.” This same test applies to other issues as well — when it comes to an...more
There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics...more
OK, I admit it. I have been — and continue to be– hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called...more
Let me paint a picture for you. It is not pretty. Unfortunately, this picture occurs all too often in the corporate governance landscape. ...more