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White Collar Crimes Tone At The Top

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 5 – CCOs Using Town Halls to Build Compliance

This week we have been exploring how Chief Executive Officers and other senior executives can set an appropriate Tone at the Top by actually walking-the-walk of compliance rather than simply talking-the-talk of compliance....more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 3-Email as a Strategic Compliance Tool

We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more

Thomas Fox - Compliance Evangelist

Tone at the Top Week: Part 1 - The Mandate

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

The Volkov Law Group

Making Corporate Culture a Reality: Define and Embed (Part I of III)

The Volkov Law Group on

Everyone has jumped on the corporate culture bandwagon.  For some new converts, they like to espouse corporate culture as a recent discovery, or a new-fangled approach for compliance programs....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

The Impact of a New CEO

The Volkov Law Group on

Businesses have to evolve in order to respond to the market, consumer demands, societal pressures and stakeholder expectations.  Companies grow and pivot in two ways – organically or through acquisition or sales of parts....more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

The Volkov Law Group on

Corporate leaders often talk to the talk when it comes to a Speak Up culture.  In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more

The Volkov Law Group

The Importance of Whistleblowers to a Speak Up Culture

The Volkov Law Group on

The twist and turns of our political world amid the ongoing controversy surrounding whistleblower reporting has focused  attention on an important issue – encouraging whistleblowers as part of a speak up culture and...more

Thomas Fox - Compliance Evangelist

Preventing White Collar Crime

I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 4 – Sentencing Considerations

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations(Antitrust...more

The Volkov Law Group

Five Important Mandates from OFAC Compliance Framework

The Volkov Law Group on

Based on its aggressive enforcement program and its recently issued Framework for Sanctions Compliance Programs, OFAC has established a new era in sanctions compliance.  Trade compliance is often siloed into its own...more

Thomas Fox - Compliance Evangelist

What is Innovation in Compliance and Why is it so Hard? Part I

One of the topics I enjoy exploring the most is all things around innovation in compliance. In fact, I dedicate an entire podcast to just that topic, which is aptly named Innovation in Compliance....more

Thomas Fox - Compliance Evangelist

Bloomsday and the Foundation of Culture

When companies come under investigation, the DOJ will ask two principal questions about the company’s compliance function. The first question is “what was the state of the compliance program at the time of the improper...more

Mitratech Holdings, Inc

How a Sports Fan Saved His Company With Compliance

In 2015, when FIFA was experiencing scandal from all sides, lifelong sports fan Pedro Castro Nevares was called in to take over the compliance function at Torneos y Competencias, a South American sports marketing firm that...more

The Volkov Law Group

CEOs Under the Criminal Spotlight – More C-Suite Misconduct

The Volkov Law Group on

We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more

The Volkov Law Group

Corporate Attitudes: When Speak Up Means Keep Quiet

The Volkov Law Group on

As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives. So, our kids start to speak up...more

The Volkov Law Group

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

The Volkov Law Group on

The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

Thomas Fox - Compliance Evangelist

Convergence of Cultural Styles to Move the Needle Forward

I continue my exploration of how to change the culture in an organization based upon a series of articles in the most recent edition of the Harvard Business Review (HBR) by Boris Groysberg, Jeremiah Lee, Jesse Price and J....more

The Volkov Law Group

Three Simple Steps to Improve Your Corporate Culture

The Volkov Law Group on

What exactly does “corporate culture” mean?  Compliance professionals often talk about how important “tone from the top” or the “mood in the middle” is, but what does that really mean?...more

Thomas Fox - Compliance Evangelist

More Compliance Lessons from Wells Fargo-FOREX Trades

At some point, you must ask just how corrupt is an organization? What does the tone from top which says to make your numbers at all cost, translate to in operationalization? Unfortunately, we have seen yet another dramatic...more

Thomas Fox - Compliance Evangelist

Mary Poppins, Corporate Culture and the Board

Corporate culture is singular to companies. Yet it also varies from industry to industry. I have been considering why the Wells Fargo scandal has engendered such public outrage. You could consider many factors, such as the...more

Thomas Fox - Compliance Evangelist

Hallmark 1 – Commitment from Senior Management and a Clearly Articulated Policy Against Corruption

Over the next two weeks I will be revisiting the Ten Hallmarks of an Effective Compliance program, as laid out in the 2012 A Resource Guide to the U.S. Foreign Corrupt Practices Act ( FCPA Guidance) authored by the Criminal...more

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