Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
In the world of compliance and risk management, one size does not fit all. Generic policies and procedures may seem like a convenient solution, but they can lead to compliance risks and potential harm. This is why the...more
You could begin with the Transparency International-Corruption Perception Index (TI-CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in...more
How does your Code of Conduct inform your risk assessment and how in turn does a risk assessment inform your Code of Conduct training? I recently visited with Charlie Voelker, Director, Compliance Products at Skillsoft and...more
Today, I consider what techniques you, as Chief Compliance Officer (CCO), can use to create continuous improvement in your compliance program. ...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more
Yesterday, I wrote about the Cardinal Health, Inc. Foreign Corrupt Practices Act (FCPA) resolution with the Securities and Exchange Commission (SEC). One of the areas that many compliance practitioners confuse is evaluating...more
The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more
The Department Of Justice (DOJ) and Securities and Exchange Commission (SEC) have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs....more
Today, I want to focus on what the compliance practitioner should do to move themselves forward professionally in 2020 and beyond. I drew inspiration from the Financial Times (FT) piece, entitled “Work in the 2020s: 5...more
As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more
How should a compliance professional think about managing risk? How about senior management? Even the Board of Directors is being called upon more and more to manage risk from its oversight perspective. I recently revisited a...more
Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more
On Monday, the Business Roundtable announced the release of the Statement on the Purpose of a Corporation(The Statement). The new Statement was signed by 181 Chief Executive Officers (CEOs) who committed to lead their...more
Once you demonstrate you are ethically challenged or maintain a moral flexibility that allows you to lie, cheat and steal; it is highly likely you will continue to do so....more
Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more
How important is due diligence on those with whom you are doing business? Why does it matter if a company is owned or controlled by a foreign government or a political party member of a foreign government? ...more
How did supply chain risk management develop? Its roots go far back and to a very different place than I expected. I recently had the chance to visit with Travis Miller, Compliance & Regulatory General Counsel at Assent...more
This year is the 15th anniversary of Affiliated Monitors, Inc. (AMI). Next week I am running a five-part podcast series on the history of AMI and the sweep of history in the rise of independent monitors as well as the...more
I thought about The Creature from the Black Lagoon in the context of how to move compliance innovation into the corporate pantheon of greater business process efficiency when I read a recent MIT Sloan Management Review...more
If you are stuck doing it in the middle of a Foreign Corrupt Practices Act (FCPA) investigation, there may well be some tension to do so and do so quickly. If you have not thought through this issue and created a process to...more
This week, on the FCPA Compliance Report, I am running a five-part podcast series on the current state of investigative due diligence. ...more