Compliance officers need to think about fraud and misconduct risks all the time, which means you need to talk to others in your organization about exactly how those risks might happen – but what’s the right way for you to do...more
Whistleblower awards from regulatory agencies seldom make news in corporate compliance circles anymore, but two recent items from the world of whistleblower awards do deserve compliance officers’ attention. They’re a reminder...more
8/9/2024
/ Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Internal Reporting ,
IRS ,
Regulatory Agencies ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers
At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more
7/3/2024
/ Anti-Corruption ,
Anti-Kickback Statute ,
Bribery ,
Chevron Deference ,
Civil Monetary Penalty ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Government Agencies ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Snyder v United States
Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more
5/29/2024
/ Anti-Corruption ,
Compliance ,
Contract Management ,
Corruption ,
Distributors ,
Due Diligence ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Recordkeeping Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Technology Sector ,
Third-Party
The U.S. Federal Trade Commission sent shockwaves through the corporate world in April when the agency imposed a ban on noncompete agreements – and like any good shockwave, this new rule will reverberate through the ethics...more
Explaining how a strong culture of ethics and compliance can help your enterprise to succeed is tricky business. So imagine my delight when I came across a recent speech from a banking regulator who did exactly that....more
Risk assessments are one of the most important tasks a compliance officer performs – and also one of the most confounding. How do you keep assessing your organization’s risks in a disciplined, methodical manner, when the...more
The U.S. Securities and Exchange Commission recently announced that its long-awaited greenhouse gas disclosure rule will be delayed yet again, most likely until April 2024. This raises an important question for compliance and...more
12/29/2023
/ Audits ,
Climate Change ,
Compliance ,
Data Collection ,
Environmental Social & Governance (ESG) ,
Greenhouse Gas Emissions ,
Proposed Rules ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Supply Chain ,
Third-Party
For the better part of a decade, the U.S. Justice Department has led the way on calls for a strong, independent corporate compliance function – until recently, that is. Then the Department of Health and Human Services leaped...more
12/8/2023
/ Board of Directors ,
CCO ,
CEOs ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Healthcare ,
Healthcare Reform ,
OIG ,
Risk Mitigation
In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more
11/30/2023
/ Acquisitions ,
Bribery ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Mergers ,
Penalties ,
Popular ,
Price-Fixing ,
Sanction Violations
For the last several weeks I have been working with NAVEX to research whistleblower protection laws across Europe. Meanwhile, several benchmarking surveys about corporate compliance programs have arrived lately, with some...more
Don’t faint from surprise at this news, but corporate compliance is a world with lots of lingo that can be difficult to understand. Case in point: a “policy about policies” – something that sounds obscure, but actually is one...more
Compliance and technology executives, we need to talk. Or, more accurately, you need to talk more often – to each other.
In the last 18 months, the Securities and Exchange Commission sanctioned three companies for making...more
As compliance officers enter 2023, they need to learn how to handle a double-edged sword: the Justice Department’s new requirement that as part of corporate misconduct resolutions, CCOs must certify the effectiveness of their...more
Workplace cultures that prioritize learning and consistently strive to eliminate harassment and retaliation do not happen overnight. It takes continuous and proactive effort to ensure employees feel safe and respected....more
Corporate compliance officers grapple all the time with what their companies should do to develop effective information protection programs. Thankfully the Federal Trade Commission has given us two recent enforcement actions...more
Corporate compliance professionals can learn a lot from the audit world. Our latest lesson comes in a statement from the Securities and Exchange Commission, warning auditors to do better at identifying the risk of fraud among...more
10/20/2022
/ Anti-Fraud Provisions ,
Chief Compliance Officers ,
Compliance ,
Compliance Management Systems ,
Corporate Management ,
Corruption ,
Fraud ,
Internal Audit Functions ,
Regulatory Requirements ,
Risk Assessment ,
White Collar Crimes