As most of you who’ve heard me speak or read my columns know, I’m a strong supporter of using data analytics in compliance programs. It’s an important tool that all compliance professionals should have a working understanding...more
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
9/4/2024
/ Compliance ,
Cooperative Compliance Regime ,
Corporate Governance ,
Corruption ,
Ethics ,
Financial Crimes ,
Forced Labor ,
Fraud ,
Governance Standards ,
Human Trafficking ,
Popular ,
Slavery ,
Supply Chain
By the time you read this, a new U.S. Department of Justice (DOJ) pilot program providing financial rewards to whistleblowers may already be underway. As I write this in late May, DOJ is in the midst of what is called a...more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Management Systems ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Internal Controls ,
Pilot Programs ,
Reporting Requirements ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more
7/31/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Civil Monetary Penalty ,
Compliance ,
Compliance Management Systems ,
Compliance Monitoring ,
Employees ,
Ethics ,
Internal Investigations ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
United Arab Emirates (UAE)
The Organisation for Economic Co-operation and Development (OECD) recently released the first edition of its Anti-Corruption and Integrity Outlook, and the report provides an interesting glimpse into the anti-corruption and...more
This year’s annual Compliance Institute (CI) provided a strong reminder of just how fortunate we are to have such a strong relationship with the U.S. Department of Health and Human Services Office of Inspector General (OIG)....more
Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more
7/15/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Communications ,
Corporate Culture ,
Corporate Governance ,
Employees ,
Ethics ,
Internal Controls ,
Policies and Procedures ,
Strategic Enforcement Plan ,
Training
Anytime a compliance violation occurs—or even a breakdown in compliance controls that doesn’t ultimately result in noncompliance—the remediation process takes center stage. And this is where questions of how and why are...more
6/4/2024
/ Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Enforcement ,
Healthcare ,
Internal Controls ,
Noncompliance ,
Policies and Procedures ,
Remediation
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
6/4/2024
/ Anti-Bribery ,
Anti-Corruption ,
Best Practices ,
Bribery ,
Chief Compliance Officers ,
Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Corporate Governance ,
Corruption ,
Ethics ,
Noncompliance ,
OECD ,
Regulatory Requirements ,
Risk Management
A recent issue of SCCE’s Corporate Compliance Weekly News contained a link to a startling report I was not previously familiar with. An investigation by the U.S. Coast Guard found numerous instances of sexual assault spanning...more
4/26/2024
/ Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Culture ,
Corporate Governance ,
Corporate Management ,
Disclosure ,
Ethics ,
Internal Controls ,
Internal Investigations ,
Risk Management ,
Self-Reporting
As we’ve noted here before, numerous environmental, social, and governance aspects have very clear compliance ramifications, whether in the form of laws and regulations or stakeholder expectations that can result in serious...more
4/26/2024
/ Chief Ethics and Compliance Officers (CECO) ,
Climate Change ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Social Responsibility ,
Environmental Social & Governance (ESG) ,
Ethics ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
In October 2023, the International Organization for Standardization (ISO) published ISO 7101, Healthcare organization management: Management systems for quality in healthcare organizations. ISO 7101 is the latest in a series...more
I’m not talking about your organization. I’m talking about that company in your vendor master files. A recent report from Moody’s found some downright silly attributes about shell companies. One that jumped out at me was the...more
Much has been written about the importance of identifying lessons learned and taking remedial action in the aftermath of an investigation into compliance failures. But an equally valuable exercise can result from exploring...more
4/1/2024
/ Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Compliance Monitoring ,
Corporate Governance ,
Failure to Comply ,
Internal Controls ,
Internal Investigations ,
Investigations ,
Remedial Actions ,
Risk Assessment ,
Risk Management
There’s good and bad news out there for compliance departments, and it’s also the same news: Governments now very much appreciate strong compliance programs.
On the one hand, that is very good (if not great!) news....more
Much is made of the need for accurate reporting in accordance with recognized standards. But this month, I’m returning to a topic I briefly touched on in July 2023, when I discussed the potential for misleading images and...more
There it is on page 39, under “Compliance Leadership and Oversight: The Compliance Officer’s Primary Responsibilities”:
“. . . the compliance officer should not lead or report to the entity’s legal or financial...more
Inspiration for this month’s column comes from our local newspaper in the Twin Cities, the StarTribune, in a column by Ross Levin. Levin discusses the psychological distinction between running towards something versus running...more
I recently read about a banker being fired for inflating his expense report to the tune of a sandwich, some pasta, and a coffee. A judge ruled in the bank’s favor in a wrongful dismissal suit filed by the former...more
Inspiration for this month’s column came from a recent article written by Amber MacArthur, who spoke at SCCE’s Compliance & Ethics Institute several years ago. I’ve followed Amber for years, often finding her writing to be...more
As reported in the Report on Research Compliance, the Office of Inspector General (OIG) of the National Science Foundation (NSF) recently held a workshop on the performance of federal research misconduct investigations....more
12/13/2023
/ Compliance ,
False Reporting ,
False Statements ,
Falsified Documents ,
Fraud ,
HHS Office of Research Integrity (ORI) ,
Investigations ,
National Science Foundation ,
OIG ,
Research and Development ,
Willful Misconduct
On July 31, the European Commission adopted the first set of rules under the European Sustainability Reporting Standards (ESRS). The ESRS is an important follow-up to the adoption of the Corporate Sustainability Reporting...more
11/6/2023
/ Compliance ,
Corporate Governance ,
Disclosure ,
Environmental Social & Governance (ESG) ,
EU ,
European Commission ,
Internal Controls ,
New Rules ,
Policies and Procedures ,
Regulatory Standards ,
Reporting Requirements ,
Sustainable Business Practices
Perhaps you haven’t pondered this question. On work-from-home days, do burglars break into their own homes? Or is this time spent doing research, preparing plans, taking online training courses on emerging best practices,...more
10/3/2023
/ Chief Ethics and Compliance Officers (CECO) ,
Compliance ,
Ethics ,
Healthcare ,
Healthcare Reform ,
Professional Development ,
Professional Networking ,
Relationship Development ,
Remote Working ,
Research and Development ,
Training
Two stories in the news recently caught my eye. In the first, a janitor allegedly shut off the power to a freezer after hearing “annoying alarms.” He ended up ruining decades of research. In the other story, an American...more
Sometimes I think we need fewer terms to describe the same or similar things. In the environmental, social, and governance (ESG) world, much is made—rightfully so—of greenwashing, which occurs when an organization makes false...more
9/11/2023
/ Climate Change ,
Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Disclosure ,
Environmental Social & Governance (ESG) ,
Fraud ,
Greenwashing ,
Misleading Statements ,
Misrepresentation ,
Sustainable Business Practices ,
Willful Misconduct