News & Analysis as of

Risk Management Compliance

Third Party Risk Management: Require ISO 37001 Certification from Your Third Parties

by Michael Volkov on

A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample guidance to companies...more

Using Movie Clips to Expand Your Compliance Classroom

by Thomas Fox on

Create unforgettable teachable moments - Instead of having lawyers drone on, giving forgettable instructions on ethics, culture and honesty; they will clearly enjoy a scene of a star like Leonardo DiCaprio bluffing his way...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

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

Activist Shareholder, the CCO and Compliance

by Thomas Fox on

t certainly is one thing for a company to make changes in their compliance program based upon ongoing monitoring, evolving best practices or remediation during an investigation. ...more

A solution to get the corporate hotline working as well as the corporate grapevine

The following interview is with Juliette Gust and Tricia Fratto, founders, Ethics Suite. RB: So, Juliette and Tricia, how about sharing some of your background? JG: Well Richard, I think I may be the only hospitality...more

COSO Framework: Fraud, Corruption and Compliance (Part I of II)

by Michael Volkov on

Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more

CCOs and CFOs: Bringing Everyone Together

by Michael Volkov on

Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and...more

A Magical Nine Days: The World Series, Houston Astros, and What It Means for Chief Compliance Officers

by Thomas Fox on

The fall saw their first World Series Championship in the 55-year history of the Houston Astros. What does it mean for the compliance practitioner?...more

Ominous Signs for the Future of the Compliance Profession

by Michael Volkov on

As we celebrate Ethics and Compliance Week in 2017, I wanted to offer my own assessment of where the compliance profession stands and the challenges facing the profession for the future....more

2017 World Series Champs – Final Lessons Learned from a Magical Nine Days

by Thomas Fox on

The 2017 World Series gave us many compliance lessons to consider going forward. We considered the role of data analytics in baseball and in compliance. The clear conclusion is that data is a tool which every compliance...more

A Team Built for Game Seven

by Thomas Fox on

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

Game 6 is Here – Empathy in Compliance

by Thomas Fox on

People rarely think of courtesy and respect as leadership skills but if you can bring these to bear in your compliance practice, you can garner greater influence as not only someone who cares but someone who cares and gets...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

What To Do When MLB Fiddles with the Equipment?

by Thomas Fox on

Sometimes the equipment you are playing with changes, particularly when that equipment is controlled by someone other than yourself. In the compliance world, this means having a compliance program which is both nimble and...more

Astros Win First World Series Game at Home – Trusting Your Eyes to Read the Data

by Thomas Fox on

There is much discussion about data analytics and Artificial Intelligence (AI) in compliance. Yet rarely do we talk about the human element in all of this. The point of data is to give you information from which you can make...more

[Webinar] Ethics & Compliance Virtual Conference - November 9th, 5:30am PT

by NAVEX Global on

Organizations that focus on creating ethical cultures come out ahead - That’s why this year’s conference theme is Ignite a Winning Workplace Culture. Winning cultures do not happen accidentally – they’re navigated by...more

Retooling Your Compliance Program

by Thomas Fox on

Today’s lesson from the world of sports informs our discussion of compliance and the risk management process; consisting of forecasting, risk assessment and risk management as a way to retool the focus of your compliance...more

Passion for Baseball and Passion for Compliance

by Thomas Fox on

The only thing that’s worse than really hard work is really hard work on something you don’t love.” As a CCO or compliance professional you will never have the financial or head count resources you need. You will have to make...more

Five Essential Steps to Improve Corporate Board Oversight and Support of Compliance

by Michael Volkov on

Corporate boards need to devote more energy to oversight and improvement of corporate culture and compliance. Over the last ten years, we have witnessed corporate scandals and misconduct that could have been prevented or, at...more

Using Strategic Risk to Your Advantage

by Thomas Fox on

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Astros in the World Series, Will Hell Freeze Over?

by Thomas Fox on

Satan called a Press Conference Saturday at midnight to announce that he was putting up his entire real estate portfolio up for immediate sale. He made this announcement on the heels of the Houston Astros win over the New...more

ISO 37001: Training, Employee Concerns, and Internal Investigations (Part V of V)

by Michael Volkov on

In my final posting on ISO 37001, I review requirements for training, raising concerns and internal investigations as part of a company’s anti-bribery risk management system....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

ISO 37001: Board, Top Management and Anti-Bribery Compliance Responsibilities (Part III of V)

by Michael Volkov on

In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more

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