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Raytheon’s Defective Pricing Fraud and Resolution (Part II of IV)

Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more

Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review [Audio]

How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Episode 331- NAVEX State of Risk and Compliance Programs [Audio]

NAVEX delivers quality studies and important insights on ethics and compliance topics. In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

NAVEX’s Report on the State of Compliance: Positive News with Serious Gaps Noted

NAVEX delivers quality studies and important insights on ethics and compliance topics.  In its 2024 State of Risk & Compliance, NAVEX provides a comprehensive report on current trends and practices involving risk and...more

Episode 327 -- Another Look at the Importance of Corporate Culture [Audio]

LRN has issued another important report -- in its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable...more

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II)

In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture.  LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

LRN’s latest report was based on a survey of more than 1,400 ethics and compliance professionals, most of whom were employed at organizations with at least 1000 employees in 19 different countries and 26 industries across...more

Boeing Reaches $51 Million Settlement with State Department for ITAR Violations

Boeing continues to struggle. As troubles mount for Boeing, it  is clear that it suffers from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory...more

Profiles in Effective CEO Leadership

One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations.  To focus on the latter, I have met some...more

The Evolution of the Compliance Profession

One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

A Compliance Reminder: Focus on Your Culture

We all agree on the importance of corporate culture.  Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture.  Compliance professionals want to...more

ECI’s New Survey – The State of Ethics & Compliance in the Workplace

The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership.  Starting in 1994, ECI has conducted a longitudinal, cross-section study of...more

The Key Elements of an Employee Reporting System (Part II of III)

Corporate leaders know what to say and when to say it – for example, a CEO may state at an employee meeting, “We want to hear your concerns. We want you to bring these concerns forward and we will address them.  We are...more

The Inextricable Link Between Ethical Culture and Profitability

Corporate governance frameworks seek to maximize management efficiency, risk mitigation, and business success.  The most important tool for accomplishing these objectives is straightforward – a Culture of Ethics and...more

A Five Step Program for Every Company to Address the New Enforcement Threats

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives.  These steps are not just suggestions nor items that can be prioritized...more

Corporate Culture: Monitor, Intervene and Remediate (Part III of III)

Once defined, installed, and surrounded with a consequence management system, a corporate culture is not fixed in stone.  To the contrary, as the business adapts through growth, innovation or in response to outside market and...more

Promoting Your Corporate Culture – Accountability and Messaging (Part II of III)

As a company’s most valuable intangible asset, we have witnessed the wreckage of companies that have fallen victim to reputational damage, scandal and ultimately the wasteland of a rotten corporate culture.  In these...more

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

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

NAVEX Global’s 2023 Hotline and Incident Management Report

NAVEX Global always provides insightful and important whitepapers and annual reports.  One of the more important annual reports is NAVEX’s Hotline and Incident Management Report. Given Navex’s important position in the...more

Bringing HR and Compliance Together for Compliance and Consequence Management (Part II of II)

The Justice Department’s recent emphasis on ethics and compliance culture, along with greater specificity on “consequence management” is a welcome breath of fresh air.  It is a policy coming for a long time and will bring...more

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

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