News & Analysis as of

Due Diligence Chief Compliance Officers

Corporate Anticorruption Compliance Programs: Ten Questions Every Board Director Should Ask

by Jones Day on

The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more

The 10 Hallmarks of an Effective Compliance Program: Still the Foundation

by Thomas Fox on

The joint Department of Justice (DOJ) and Securities and Exchange Commission (SEC) 2012 FCPA Guidance came out five years ago this month. As a commentator focusing on the doing of compliance, we should pause to once again...more

Compliance and Technology – Rational Actors Need to Adopt Technology

by Michael Volkov on

I always enjoyed the assumption underlying economic models – assuming people are rational actors, then . . . Sometime people do not act rationally, and sometimes people react out of fear or make unrealistic assumptions....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

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

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

Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring

by Thomas Fox on

Continuous improvement can take many ways, shapes and forms. Typically, when it comes to third-party risks, a Chief Compliance Officer (CCO) or compliance professional will consider the ownership structure to see if there is...more

Retaining a “Risky” Third-Party

by Michael Volkov on

Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or...more

FCPA Risks and Acquisition Integration Challenges

by Michael Volkov on

Chief compliance officers have devoted significant efforts to conducting pre-acquisition due diligence of a proposed target companies. I do not intend to diminish the importance of pre-acquisition due diligence, but I have...more

Knowing Your Employees and Incident Management Systems

by Michael Volkov on

Chief compliance officers know the importance of trust, not just as a foundation of a global company’s compliance program, but in the context of knowing what company employees are doing out in the field. CCOs will always say...more

Leadership Lessons from Catch-22

by Thomas Fox on

Joseph Heller’s Catch-22 is one of the most famous books and movies from the second half of the 20th century. While it may not seem apparent on first blush, it has several lessons for the Chief Compliance Officer (CCO) to...more

Legal and Compliance Coordination – An Essential Foundation to an Effective Compliance Program (Part IV of IV)

by Michael Volkov on

Here is a profound grasp of the obvious – Lawyers can be difficult people. Some like to condemn the profession in its entirety (and carry with them a collection of lawyer jokes). As an attorney, I beg to differ. Many...more

Meeting the challenges of Customs compliance: 11 questions to ask yourself, 6 action steps

by DLA Piper on

In the global environment in which we operate, exchanging goods internationally always entails basic customs issues.  Among these are the import/entry process, tariff classification, valuation, country of origin labeling, and...more

Recent DOJ Guidance Highlights Substantial Benefits of Being Proactive About Compliance

by Epstein Becker & Green on

The Criminal Fraud Section of the U.S. Department of Justice (DOJ) recently released guidance entitled “Evaluation of Corporate Compliance Programs,” setting forth over 100 questions in 11 categories that the Fraud Section...more

Infusing Your Compliance Program with Business Ethics

by Michael Volkov on

It is important to remember that companies are required to implement an ethics and compliance program. Ethics should not ever be a segregated issue carved off from a compliance program. They walk hand-in-hand, and reinforce...more

Embraer FCPA Enforcement Action – Part II

by Thomas Fox on

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

“Reason To Know” – A Chilling Term For Exporters

by Williams Mullen on

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

Hallmark 7-Third-Party Due Diligence and Payments

by Thomas Fox on

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Due Diligence Questions Chief Compliance Officers Should Ask In A Job Interview

The following guest post is by Maurice Gilbert, Managing Partner of Conselium Executive Search. Earlier this month I posed a question to Chief Compliance Officers around the world: “Since today’s regulatory climate means...more

Third Party Risk Management Not Just Due Diligence

by Michael Volkov on

The term “due diligence” is an overused expression in the compliance world. It has become a term to mean heightened concern or investigation. No one can really define what it means except to say it has different meanings in...more

Due Diligence Questions Chief Compliance Officers Should Ask In A Job Interview

by Thomas Fox on

Ed. Note-Today I have a guest post from Maurice Gilbert, Managing Partner of Conselium Executive Search. In today’s regulatory climate, the Chief Compliance Officer faces increased personal liability for corporate...more

The Panama Papers and Shell Games, Part I

by Thomas Fox on

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

The SEC, CCOs and Compliance Programs

by Dorsey & Whitney LLP on

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Broker, Compliance Officer Fined For AML Failures

by Dorsey & Whitney LLP on

Money laundering continues to be a key focus of regulators. Recently, for example, FINCEN Director Jennifer Shasky Calvery discussed money laundering through real estate transactions. Earlier this year the SEC brought an...more

SEC Affirms Sanctions on Stanford’s CCO

by Burr & Forman on

The SEC recently affirmed its ALJ’s ruling barring Alan Stanford’s former CCO from the industry and ordering monetary penalties of $260,000 together with $591,992 in disgorgement. The Commission held the CCO approved false...more

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