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Chief Compliance Officers Compliance

From the Mummy’s Tomb to the Mummy’s Ghost to Professional Development

by Thomas Fox on

Too often your learning goals suffer because you are too busy or too tired to even think about it. Or because you have no time and have other obligations. Yet there is no job, particularly the compliance profession, in which...more

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

by Michael Volkov on

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more

ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)

by Michael Volkov on

In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more

Liz Wiseman-Multiplying the Influence of Compliance

by Thomas Fox on

On the second full day of the SCCE Compliance and Ethics Institute (CEI) Liz Wiseman was one of the keynote speakers. Wiseman is the co-author with Greg McKeown of Multipliers: How the Best Leaders Make Everyone Smarter,...more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

SCCE Preconference Learning – You Are Not Alone in Compliance

by Thomas Fox on

I am writing this today from the Society of Corporate Compliance and Ethics (SCCE) 2017 Compliance and Ethics Institute (CEI). This is the largest annual gathering of compliance professionals anywhere and it is already off to...more

The Mummy’s Hand and a Risk-Based Approach at the Board Level

by Thomas Fox on

Today we consider the 1940’s film, The Mummy’s Hand as the second installment in Universal Pictures series featuring this creature. Boris Karloff departed the role and it was taken over for one film by Tom Tyler, who was...more

Lawyers Can Be A Positive Force for Compliance

by Michael Volkov on

Lawyers get a bad rap, and I am not just referring to all the lawyer jokes we have heard numerous times. Lawyers get a bad rap when it comes to compliance. Much of it is not deserved – but candidly, some of it is deserved....more

In Defense of Compliance Checklists

by Michael Volkov on

Compliance officers have to avoid complicating a compliance program. As in many areas in life, there is a value in simplicity. Take for example a compliance training presentation. If a compliance officer overwhelms his/her...more

An Exploration of Soft Skills in Remediation for the Chief Compliance Officer

by Thomas Fox on

Many have focused on the more technical aspects of the remediation component of a potential Foreign Corrupt Practices Act compliance violation. I wanted to explore the soft skills that a CCO must use, both internally and...more

Compliance Meaningfulness: Hard to Achieve, Easy to Destroy

by NAVEX Global on

This post originally appeared on the Richard Bistrong, Front-Line Anti-Bribery Blog, www.richardbistrong.com and is reposted with the permission of Richard Bistrong. In an article titled, What Makes Work Meaningful- Or...more

The Delusion of a Bare-Bones Compliance Program

by Michael Volkov on

Instead of wrestling over the definition of an “effective” ethics and compliance program, let’s take a step back and define what we all agree on is an “ineffective” compliance program. Unfortunately, when you work in the real...more

What a CCO Can Learn from Da Vinci

by Thomas Fox on

When Walter Isaacson publishes a book, you would do well to read it. His previous books have included biographies of such disparate luminaries as Steve Jobs, Albert Einstein, Henry Kissinger and Benjamin Franklin. My personal...more

Lessons for Compliance Officers from Hurricane Harvey and Other Historic Weather-Related Events

by Thomas Fox on

Lessons for the corporate compliance professional from Hurricane Harvey and other weather-related disasters....more

How much is at stake for whistleblowers?

by Bryan Cave on

Whistleblowing and the ongoing compliance debate keep the media and the wider press busy and readers alert. And yet these days, executives of reputed global companies are finding themselves imprisoned for fraud and other...more

Day 20: What Does Innovation in Compliance Look Like?

by Thomas Fox on

As I end this section on innovation, I want to conclude by laying out a road map which allows a CCO or compliance practitioner to make more effective and better operationalize a corporate compliance program. With the DOJ’s...more

The Compliance Conundrum — Spending Money to Save Money

by Michael Volkov on

Chief compliance officers have to be honest with themselves. While I am optimistic about the growing importance of the compliance function, I remain concerned that CEOs and senior management are slowly strangling ethics and...more

The Five Most Important Issues for a CCO to Report to the Board

by Michael Volkov on

Chief compliance officers have to throw out their template for charts, diagrams and data that they use to report to the Audit/Compliance Committee and start over. Slick and colorful charts and diagrams are great but CCOs are...more

Ethics and Compliance Controls – Different Means to the Same Objective

by Michael Volkov on

People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more

Compliance Lessons From Burner Phones

by Thomas Fox on

Hunter S. Thompson once said that when the going gets weird, the weird turn pro. It turns out that amateurs can get weird too. The University of Mississippi football program, which is under a self-imposed postseason ban and...more

No More Excuses: CCOs Have to Embrace Technology

by Michael Volkov on

It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more

Criminal justice: How best to stop economic crime

by WilmerHale on

Speaking at the 35th annual Cambridge International Symposium on Economic Crime, Robert Buckland QC MP, the Solicitor General for England and Wales, and David Green QC, Director of the SFO, addressed the question, “Preventing...more

Farewell to a Repo Man and Using Laconic Persuasion as a CCO

by Thomas Fox on

The life of a Repo Man is always intense… That was one of the greatest lines from one of the greatest movies from one of the greatest laconic actors of all time. Of course it was Harry Dean Stanton who died over the...more

4 Signs of a Poor Relationship Between a CCO and the Board

by Michael Volkov on

Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more

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