Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Implications of the SEC Cybersecurity Disclosure Rule
The Privacy Insider Podcast Episode 4: Don't Be Evil: In the Hot Seat of Data Privacy, Part 1
Privacy Issues from Third-Party Website Tags
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Managing Social Media Risk
Compliance Lessons from Dating in Your 50s
Managing Compliance Risk for Human Trafficking and Modern Slavery
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
Preparing for a Government Healthcare Audit
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Understanding the HHS OIG’s General Compliance Program Guidance
Climate Risk, the emerging risk
What's Going on with FCPA?
Compliance, Project Management, and Process Improvement
Leaning in on AI in Compliance Programs
PODCAST: Williams Mullen's Gavels & Gowns - Title IX Regulations - Changes on the Horizon
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
This week we have been exploring how Chief Executive Officers and other senior executives can set an appropriate Tone at the Top by actually walking-the-walk of compliance rather than simply talking-the-talk of compliance....more
Compliance professionals can face a lot of resistance in the course of their work: leaders who don’t have the time, budget limits, managerial indifference, and even outright hostility. But, sometimes the impediments are...more
LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael...more
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
You may not realize it, but your compliance program has a brand. Line employees and management all have a host of impressions about the compliance department that color how they respond to what you say and do. A strong brand...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
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
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
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
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
Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more
On March 25, 2022, Kenneth Polite, Assistant Attorney General for the Department of Justice (DOJ)’s Criminal Division, delivered a speech at NYU Law School’s Program on Corporate Compliance and Enforcement announcing...more
Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is...more
On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more
Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry. Compliance...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
While the value of a positive corporate culture is clear, a strong culture does not always develop organically. Companies must devote attention to measuring, managing, and promoting ethical cultures....more
We often discuss the importance of a “Speak Up” culture. We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization....more
Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more
Chief compliance officers (CCOs) are talented professionals. As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation. CCOs focus on legal and compliance risks...more
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
Chief compliance officers are heroes. They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more
The Justice Department “listens and learns” from companies and compliance practitioners. As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more
I have been thinking quite a bit about the future of the corporate compliance function. Our profession seems to be an inflection point, moving away from the lawyer-driven written policies and procedures to a more...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more