To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
The Department of Justice (DOJ) has unveiled a new whistleblower policy designed to incentivize individuals to disclose corporate misconduct through financial rewards from any resulting forfeiture of criminal proceeds. The...more
Key Takeaways - As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more
To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more
Yesterday I introduced, with the help of the Red Baron, the topic of a Compliance Center of Excellence (CCoE). Today I want to expand out into how a Chief Compliance Officer (CCO) or compliance practitioner would design a...more
Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs. From my vantage point, the set of challenges can be different depending on the industry. Global...more
If you do not believe in the compliance regime that you are pushing, it will be nearly impossible for the rest of your far-flung corporate work force to believe in it. Talk about compliance and the positive aspects of your...more
How agile is your compliance program? How does this fit into the operationalization requirement laid out in the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation)? While many have argued...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more