Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
Implications of the SEC Cybersecurity Disclosure Rule
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
Privacy Issues from Third-Party Website Tags
False Claims Act Insights - If Everything Matters, Nothing Does: Parsing Materiality in FCA Disputes
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Social Media Risk
FCPA Compliance Report: Erica Salmon Byrne on Closing The Speak Up Gap
Principled Podcast: S11E7 | Fortifying Ethical Frameworks: Navigating Emerging Risks in the Middle East
Episode 327 -- Another Look at the Importance of Corporate Culture
In Brief: Election Law & Government Ethics Unpacked: National Convention Guidance
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
Episode 318 -- LRN's Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership
Principled Podcast: S11E6 | Ethics & Compliance Evolution in Singapore: Adapting to Global Risks
Episode 315 - Boeing Pays $51 Million for ITAR Violations
Episode 312 -- Eddie Green, CEO SnippetSentry, on Communications Preservation Risks
Behavioral Health Compliance
The EU Whistleblowing Directive
In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more
Board Oversight of the Compliance Program - The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be...more
Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more
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
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more
On July 16, 2019, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule, entitled “Requirements for Long-Term Care Facilities: Regulatory Provisions To Promote Efficiency, and Transparency,” that, if...more
On April 30, the Criminal Division of the Department of Justice released an update to the Fraud Section’s February 2017 guidance document titled “Evaluation of Corporate Compliance Programs.” ...more
On May 1, 2019, the Criminal Division of the U.S. Department of Justice (DOJ) released updated guidance for prosecutors to utilize in assessing whether an organization had in place “an adequate and effective corporate...more
How is the #MeToo movement driving demand for greater personal accountability from both workers and management?...more
Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs. From my vantage point, the set of challenges can be different depending on the industry. Global...more
If you do not believe in the compliance regime that you are pushing, it will be nearly impossible for the rest of your far-flung corporate work force to believe in it. Talk about compliance and the positive aspects of your...more
When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more
I am not one to beg but I have decided I have nothing to lose here – please, when it comes to compliance, everyone has to adopt a new mantra. The purpose of compliance is not to prevent legal and code of conduct violations....more
The messaging behind the need for companies to implement robust compliance programs continues to suffer from a narrow conception of the overall compliance function. It is easy to get lost in the weeds on compliance programs...more
This week, I am exploring issues related to compliance and ethics training, inspired by an article in the online publication, Slate, entitled “Ethics Trainings Are Even Dumber Than You Think”, by author L.V. Anderson. Today I...more
In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more
The compliance profession faces many challenges. Some are more important than others. When it comes to evaluating performance, or measuring compliance programs, the profession has a steep uphill climb....more
Chief compliance officers and senior executives wrestle with strategies to spread and embed important compliance messages. A CEO and senior executives can spread a compliance message but they are always battling competing...more