News & Analysis as of

Risk Mitigation Compliance Chief Compliance Officers

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

The CCO as a Futurist

by Thomas Fox on

Every Chief Compliance Officer (CCO) and compliance practitioner who thinks about their compliance program one, three or five years down the road is a budding futurist. The Compliance Week 2017 Annual Conference opened this...more

Compliance is Not “Rocket Science”

by Michael Volkov on

In the compliance arena, like in many others in life, we value simplicity. I have repeatedly stressed the importance of compliance initiatives that are relatively simple. Too often, lawyers and compliance professionals...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

DOJ Fraud Section Unveils Blueprint for Assessing Corporate Compliance Programs

by White & Case LLP on

In the year and a half that has transpired since the DOJ's Fraud Section retained a compliance consultant to assist prosecutors' evaluation of compliance programs, compliance officers, general counsels and white-collar...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

CCOs Cannot Ignore C-Suite Risks

by Michael Volkov on

As the headlines continue to point to major misconduct and scandals involving senior corporate executives, compliance officers need to refocus their efforts and address a critical need....more

Doing the Two-Step: Prioritizing Risks and Allocating Resources

by Michael Volkov on

Chief compliance officers face imposing tasks on a daily basis. The tasks often look insurmountable and it is easy for CCOs to just turn away and find a more manageable set of tasks....more

Shakespeare Week – Part I: Henry IV, Part II – Lawyers and Compliance

by Thomas Fox on

What is the most famous line in Shakespeare about lawyers? That is an easy one because lawyer-haters across the world (and lawyer-lovers as well) know it – First thing we do is kill all the lawyers. It comes from Henry IV,...more

Building and Managing the Right Team for Compliance

by Thomas Fox on

On this date in 1929, Walter Chrysler was announced as Time Magazine’s Man of the Year. Chrysler was a seminal figure in the American automobile industry in the last century and in business leadership. He grew his company to...more

A Compilation of Enforcement and Non-Enforcement Actions

by Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Spain Sets a New Milestone with its Corporate Compliance Statute

by Foley & Lardner LLP on

As of July 1 of this year, Spain becomes the latest in a string of nations with a corporate compliance defense. Article 33 of Spain’s criminal code will provide an exemption from corporate criminal liability where the company...more

Latin America Corruption: Keep Calm, Carry On?

by Shearman & Sterling LLP on

Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in...more

Boeing Kickback Case Underscores Critical Importance of Compliance Programs - Government Contractors Must Be Proactive in...

by Holland & Knight LLP on

In the words of F. Scott Fitzgerald, "Show me a hero and I'll write you a tragedy." When the hero of the day is a company's compliance program, it's almost a surefire bet that that a tragedy is being written. But at the same...more

A Neglected Compliance Task: Program Assessments

by Michael Volkov on

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. – Groucho Marx - Sometimes compliance practitioners miss the forest from the trees. They can get lost in the details of their...more

FCPA Compliance and Ethics Report-Episode 147-Prof. David Orozco on the use of compliance as a business strategy

by Thomas Fox on

In this episode I visit with Florida State University Professor David Orozco about his recent article on the use of corporate legal as a business strategy and its implications for the compliance practitioner. ...more

Practical Advice on Risk and Compliance Program Assessments

by Michael Volkov on

Sometimes the compliance industry makes things harder than they really need to be. As a result, Chief Compliance Officers are left to modify and transform practices and tools to fit the real world. I understand why CCOs do...more

Fleet-Footed Investigations and Prompt Remedial Action: The New Normal

by Littler on

Does your company respond to all internal concerns immediately, investigate them thoroughly and remediate them with unmatchable speed? What if the concern comes from an officer, director, lawyer, compliance professional,...more

Making the Case for Compliance Training for Third Parties

by NAVEX Global on

How to make the case for implementing third party compliance training in your organization. A recent article in the San Francisco Chronicle profiled Jay Jorgensen, the new Global Chief of Compliance at Walmart. The...more

COSO and Internal Controls – Part V

by Thomas Fox on

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

COSO and Internal Controls – Part III

by Thomas Fox on

This post continues my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

2015 Trends: #8 Top Whistleblowing Priorities for Compliance Professionals

by NAVEX Global on

Last November, the U.S. Securities and Exchange Commission issued its Annual Report to Congress on the Dodd-Frank Whistleblower Program. It is clear that the program is going strong. Following are five key ways compliance...more

Both Sides Now and Asking the Right Compliance Questions

by Thomas Fox on

One of my favorite singers has always been Judy Collins. Like most of us, I was introduced to her through her interpretation of Joni Mitchell’s song Both Sides Now which she released in 1967. Joni Mitchell did not record her...more

Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

by Thomas Fox on

“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more

Kickbacks and Bribery

by Michael Volkov on

Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues....more

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