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Chief Compliance Officers Individual Accountability

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Miles & Stockbridge P.C.

Individual Accountability Expanded: DOJ Launches Corporate Compliance Pilot Program Focused on Compensation System and Clawbacks

The U.S. Department of Justice (DOJ) announced Friday a three-year pilot program related to its continued efforts to hold individuals directly accountable for corporate wrongdoing. The two-pronged program incentivizes...more

NAVEX

Three Lines of Defense for Risk Management

NAVEX on

In our continuing quest to improve how companies manage risk, it’s inevitable we’d eventually discuss the “Three Lines of Defense,” a risk management model for clarifying roles and responsibilities. It explains the...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Thomas Fox - Compliance Evangelist

What is Innovation in Compliance and Why is it so Hard? Part III

Over the past few blog posts, I have been exploring a recent article in Harvard Business Review by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”. Pisano says the conventional wisdom is innovative...more

Thomas Fox - Compliance Evangelist

Up Close and Personal: Individual CCO Liability – Part II

Yesterday I began an exploration of the potential individual liability of a Chief Compliance Officer (CCO) based upon the Financial Industry Regulatory Authority (FINRA) enforcement action against Raymond James Inc. and its...more

Thomas Fox - Compliance Evangelist

New DOJ Guidance and FCPA Pilot Program, Part I-Introduction

Last week the Department of Justice (DOJ) held a Press Conference, open to all, led by Andrew Weissmann and Leslie Caldwell. At this Press Conference, they announced the culmination of several ongoing initiatives into a new...more

Manatt, Phelps & Phillips, LLP

Raising the Stakes for AML Compliance Officers: Court Refuses to Rule Out Potential Liability for Role in Employer's BSA...

Why it matters - A federal court judge in Minnesota has rejected the motion of a former chief compliance officer to dismiss the U.S. government's claim that he is liable under the federal Bank Secrecy Act for his...more

The Volkov Law Group

Compliance Program Effectiveness Requires Accountability

The Volkov Law Group on

A compliance program requires accountability. You can have ethics and you can have compliance policies, procedures and all the bells and whistles, but someone has to be accountable....more

The Volkov Law Group

“Sympathy” for the Board

The Volkov Law Group on

Corporate boards have been under siege. If you ask a Board member about the changes in corporate governance, risk and accountability, they roll their eyes and lament that the job of a board member has become more complicated...more

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