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Chief Compliance Officers White Collar Crimes Internal Controls

Health Care Compliance Association (HCCA)

So many reporting systems!

By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more

Thomas Fox - Compliance Evangelist

Compliance Lessons from The Adventure of the Crooked Man

One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more

The Volkov Law Group

Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report

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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

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more

The Volkov Law Group

The Evolution of the Compliance Profession

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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

The Volkov Law Group

Episode 284 -- How to Implement a Compliance Compensation System

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The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management.  The theoretical...more

The Volkov Law Group

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

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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

The Volkov Law Group

Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

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Chief compliance officers have a lot of issues to balance on their plate.  Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more

The Volkov Law Group

The Importance of Ethics and Compliance to the Overall Corporate Mission (Part II of IV)

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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

Society of Corporate Compliance and Ethics...

Salvador Dahan on the Journey of Petrobras

Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more

The Volkov Law Group

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

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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

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

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“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

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

Latham & Watkins LLP on

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

The Volkov Law Group

Compliance Understanding of Business Processes

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Compliance understanding of business processes is a critical part of understanding internal controls and a company’s risk profile.  Compliance officers are adept in identifying and assessing risks.  In doing so, a compliance...more

Jones Day

DOJ Updates Its "Evaluation of Corporate Compliance Programs" Guidance

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The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors. The Result: The updates provide additional insights into the factors the DOJ is...more

Thomas Fox - Compliance Evangelist

Continuous Improvement in a Compliance Program

Today, I consider what techniques you, as Chief Compliance Officer (CCO), can use to create continuous improvement in your compliance program. ...more

The Volkov Law Group

Admit It – Your Compliance Program is Not Really “Effective”

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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 Volkov Law Group

Incident Data and Intra-Company Cooperation

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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

Thomas Fox - Compliance Evangelist

Filling the Shoes as a First Time CCO

Moving to the Chief Compliance Officer (CCO) chair can be quite a daunting challenge. The first time you do so can bring feelings of fear leading to terror. However, everyone who has moved up to a leadership position in any...more

Thomas Fox - Compliance Evangelist

What to Ask Before You Begin a Large Compliance Project

As most compliance professionals are lawyers with legal training, they have little actual experience with implementing new process-based projects. Russ Berland, Chief Compliance Officer (CCO) at Aventiv Technologies, LLC, has...more

The Volkov Law Group

Keeping Your Eye on the Risk Ball

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Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces.  I am exaggerating a little bit to make...more

The Volkov Law Group

The Future of Compliance: Building Bridges (Part II of III)

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As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance.  Good compliance means good business – we all know that....more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

CCO Lessons from A Charlie Brown Christmas

Delegation is always a key technique in improving productivity. However, you should not simply “shove things off your plate” but use the opportunity to give specific and new challenges to employees to help in their own career...more

Thomas Fox - Compliance Evangelist

Monitor Independence and Evolution

I recently had the chance to sit down with Mikhail Reider-Gordon, Managing Director of Global Affairs at Affiliated Monitors, Inc. (AMI), for a five-part sponsored podcast series. One of the key themes was why independence in...more

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