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C-Suite Executives Foreign Corrupt Practices Act (FCPA) Chief Compliance Officers

American Conference Institute (ACI)

[Event] International Conference on Anti-Corruption - June 17th - 18th, London, United Kingdom

Cross-jurisdiction cooperation in the fight against international corruption and bribery is intensifying. The UK’s Serious Fraud Office (SFO), France’s National Financial Prosecutor’s Office (PNF), and Switzerland’s Office of...more

Womble Bond Dickinson

DOJ Raises Stakes on Corporate Compliance: How to Respond

Womble Bond Dickinson on

Even at companies with separate legal and compliance departments, Department of Justice-enforced compliance is a key concern for in-house counsel. Those pressures only will increase in the near future and are rapidly...more

K&L Gates LLP

What the C-Suite and Board Should Know About the New CCO Certification Requirement from DOJ

K&L Gates LLP on

U.S. Department of Justice (DOJ) Deputy Attorney General Lisa Monaco presented a new policy at a Securities Industry and Financial Markets Association event that requires chief compliance officers (CCO) to certify that...more

Thomas Fox - Compliance Evangelist

The Role of HR in Creating an Ethical Culture

The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more

Health Care Compliance Association (HCCA)

[Event] Board & Audit Committee Compliance Conference - February 24th - 25th, Fort Lauderdale, FL

The Office of Inspector General of Health and Human Services expects board members, board audit/compliance committee members, and senior level leaders of organizations to be experienced in compliance oversight. The Board &...more

The Volkov Law Group

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

The Volkov Law Group on

The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

The Volkov Law Group

The Emperor Has No [Compliance Program]

The Volkov Law Group on

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make....more

The Volkov Law Group

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

The Volkov Law Group on

When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

The Volkov Law Group

CCOs Cannot Ignore C-Suite Risks

The Volkov Law Group on

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

The Volkov Law Group

When Lawyers Cross the Line – Breaking Bad Under the Law

The Volkov Law Group on

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more

Foodman CPAs & Advisors

Are Compliance Officers at Financial Institutions Now in the Hot Seat for Fines?

Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more

Thomas Fox - Compliance Evangelist

CCO Independence, Authority and Resources as Indicia of an Effective Compliance Program

At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s...more

Thomas Fox - Compliance Evangelist

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

The Volkov Law Group

Who Can Fire a CCO?

The Volkov Law Group on

There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider....more

Thomas Fox - Compliance Evangelist

Compliance Counsel Metrics – Part III: Program Evolution and Incentivizing Compliance

Today, we continue our exploration of the new Department of Justice (DOJ) Compliance Counsel and the metrics laid out by Assistant Attorney General Leslie R. Caldwell who called for her review of compliance programs. These...more

Thomas Fox - Compliance Evangelist

Good-Bye to Maureen O’Hara and How to Drive Compliance into the DNA of Your Company

Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne. Testament to the fiery...more

Thomas Fox - Compliance Evangelist

Compliance at the Tipping Point, Part V – Protection Afforded From a Compliance Program

Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2015

Welcome to the August 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

Thomas Fox - Compliance Evangelist

The Third Man and the Authority of Chief Compliance Officers

Harry Lime is back, although he really never left us. As reported by Kristin M. Jones in a Wall Street Journal (WSJ) article, entitled “Harry Lime Reborn”, the glorious British film noir The Third Man, written by Gra ham...more

Thomas Fox - Compliance Evangelist

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the...more

Thomas Fox - Compliance Evangelist

Compliance Risk Logic’s Mastering Compliance in International Markets Conference

If you are in the Far East there is now a master conference centered around the top compliance practitioners in the region. Next month, from June 8-9, Compliance Risk Logic is putting on its a conference in Singapore,...more

The Volkov Law Group

The Two Ps of Compliance: Promote and Protect

The Volkov Law Group on

I often complain about compliance messaging. Compliance officers have to be careful to avoid becoming viewed as “nattering nabobs of negativism,” as former Vice President Spiro Agnew famously stated about the liberal media....more

Thomas Fox - Compliance Evangelist

Why Tone at the Top Matters and Join the FCPA Professor in Houston

Over this week I have looked at some issues related to compensation and methods from other disciplines that a compliance practitioner might use to test and then improve a company’s third party management regime. Today, I want...more

Thomas Fox - Compliance Evangelist

Gary Owens, Laugh-In and Accountability in Your Compliance Program

If you were alive at all during the 1960s, you will recall that one of the cultural phenomenon’s was NBC’s television show Laugh-In. It was brought to you from the NBC studios in beautiful downtown Burbank and featured one...more

Thomas Fox - Compliance Evangelist

Bone-headed Moves on the Football Field and Idiotic Statements About Corruption

That football truism (allegedly) came from former Texas Longhorn head coach Darrell Royal. While he intoned it in a different era, Pete Carroll and his Seattle Seahawks proved it still to be valid in the most recent Super...more

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