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Chief Compliance Officers

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

by Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Farewell to Hall Greer: The Role of a Compliance Committee Chair – Part I

by Thomas Fox on

I continually advocate that a Boards of Directors should include a compliance professional and that there should be a Compliance Committee Chair on the Board, handling ethics, compliance, #MeToo and other reputational issues,...more

CCOs and Compromising Positions

by Michael Volkov on

The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more

Environmental, Social and Governance (ESG) and Impact Enter the Board Room

by Womble Bond Dickinson on

[co-author: Mark Newberg, Director of Impact Strategies] Recently, Larry Fink, the CEO of BlackRock, the world’s largest asset manager, took a noteworthy step in an open letter he wrote to the CEO’s of all publicly traded...more

The New Test for CCOs

by Michael Volkov on

These are inspiring times for the compliance profession. Looking back on the last ten years, it is amazing to observe the growth and influence of the compliance profession. Many of the original advocates for the compliance...more

Podcast - Risk Mitigation & Management: Bringing a Compliance Program to Life

by Ropes & Gray LLP on

[co-speaker: Hui Chen, former Department of Justice Compliance Counsel] Compliance programs are difficult to design, and implementing and enforcing policies and procedures is challenging, especially in complex, global...more

Bringing a Compliance Program to Life: Connecting the Dots

by Michael Volkov on

A compliance program is an interdependent function that gains exponentially from coordination and cooperation with key functions. CCOs have to be politicians and they have to develop effective interpersonal skills. Without...more

10 Top Ways to Be a Wildly Effective Compliance Officer

by NAVEX Global on

As the world’s regulators penalize companies with higher and higher fines for corporate misconduct, compliance officers are becoming critical lynchpins to protect the company, stop executives from going to jail and prevent...more

FCA Proposes New Guidance on Financial Crime Systems and Controls

by Latham & Watkins LLP on

The FCA is proposing to add a new chapter on insider dealing and market manipulation to its Financial Crime Guide. Key Points: ..The FCA proposes to add a new Chapter 8 to Part 1 of its Financial Crime Guide, outlining...more

The State of Affairs: General Counsels and Chief Compliance Officers

by Michael Volkov on

In the last few years, the tension between chief compliance officers and general counsels appears to have subsided. The issue of separating CCOs from legal departments is not as important as it used to be. Why?...more

Kinross-Lessons Learned on Internal Controls and Internal Audit

by Thomas Fox on

Yesterday the Securities and Exchange Commission (SEC) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action involving Kinross Gold Corporation (Kinross). ...more

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

by Latham & Watkins LLP on

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2017, and outlook for 2018. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

11 Key Takeaways for Updating your Compliance Program in 2018: Investment Advisers, Hedge Funds and Private Equity Funds

Based on our review of the investment adviser regulatory landscape of 2017, these are the top 11 recommendations for investment adviser CCOs for updating their compliance programs....more

10 Hallmarks of an Effective Compliance Program - #5 Communication and Training

by Thomas Fox on

Episode Five of a ten-part series for compliance professionals. In this new series of audio white papers, Thomas Fox looks at the 10 Hallmarks of an Effective Compliance Program. Hallmark #5: Training and...more

Zero-Tolerance on Sexual Harassment Goes Beyond Resolving Individual Incidents

by NAVEX Global on

This blog is part of the You Can't Delegate Ethics campaign. The campaign posits that systemic change on the issue of sexual harassment will occur only when good people in power take responsibility for the issue and create...more

Another Way Sexual Harassment Is Pernicious | #YCDEthics

by NAVEX Global on

We shouldn’t mince words: sexual harassment is morally repugnant. I wish that’s all we had to say to make it end. However, in life, there are times when what is morally right doesn’t win out and people behave wrongly,...more

Practical Suggestions on ‘Why Compliance Programs Fail’

I recently cracked open my Harvard Business Review to the article on “Why Compliance Programs Fail.” I read with great interest the authors’ theory on how weak, milk-toast metrics can result in check-the-box, paper-only...more

Compliance Needs to Understand Business

by Michael Volkov on

A chief compliance officer needs to be independent and have adequate authority within the organization. But do not get confused by the concept of independence. Compliance depends on collaborative relationships with other...more

10 Hallmarks of an Effective Compliance Program - #4 Risk Assessments

by Thomas Fox on

Episode Four of a ten-part series for compliance professionals. In this new series of audio white papers, Thomas Fox looks at the 10 Hallmarks of an Effective Compliance Program. Hallmark #4: Risk Assessment....more

Five Questions for Corporate Boards on Oversight of Compliance

by Michael Volkov on

Let’s face it – corporate boards are not adept at overseeing a company’s compliance program. In the absence of a board member who has prior compliance expertise, corporate boards either ignore or struggle to fulfill their...more

Agile Compliance = Operationalized Compliance: Part I – Coaching

by Thomas Fox on

Agile is not often a work method associated with compliance programs or the compliance profession. That may be from the heritage that many compliance practitioners came out of the General Counsel’s office or private practice...more

The Fall of the Alamo: Analogy for Compliance Officers?

by Thomas Fox on

What happens to a Chief Compliance Officer (CCO) or compliance practitioner when they have to make a stand? Do they make the ultimate corporate sacrifice? Will they receive the equivalent of a corporate execution as the...more

10 Hallmarks of an Effective Compliance Program - #3 CCO Authority & Compliance Function Resources

by Thomas Fox on

Episode Three of a ten-part series for compliance professionals. In this new series of audio white papers, Thomas Fox looks at the 10 Hallmarks of an Effective Compliance Program. In this audio white paper, a focus on Chief...more

DOJ to Apply FCPA Corporate Enforcement Policy as "Nonbinding Guidance" to Other Crimes

by Bryan Cave on

DOJ’s Acting Head of the Criminal Division, John Cronan, announced publicly that the FCPA Corporate Enforcement Policy, which is now part of the U.S. Attorney’s Manual and is considered formal guidance for FCPA cases, would...more

Farewell to Sir Roger Bannister and Hello to the New Braskem

by Thomas Fox on

I have previously considered how a Chief Compliance Officer (CCO) should take steps in remediation after a corruption incident. I was therefore intrigued by the remarks from a CEO on how he worked to keep a company upright....more

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