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Internal Controls Corporate Culture Corruption

Thomas Fox - Compliance Evangelist

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 5- A Case Study for Compliance

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

Bank of America’s Corporate Culture Crisis: Part 3-The Role of Internal Controls

Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more

Thomas Fox - Compliance Evangelist

The Boeing Plea Agreement-A Major Disconnect

In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more

Thomas Fox - Compliance Evangelist

The Boeing Monitorship – Compliance, Accountability, and the Path Forward

When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more

The Volkov Law Group

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

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Transforming a Corporate Culture in Crisis: Lessons from Boeing

There has not been a company which has had a run of worse publicity in 2024 than Boeing. Unfortunately it has been self-inflicted. I recently participated in a webinar with Sam Silverstein on what Boeing can do to try and...more

Thomas Fox - Compliance Evangelist

2023 Global Business Ethics Survey: Part 5-Workplace Ethics Concerns and the Need for Compliance

In a recent ECI podcast series , I had the opportunity to visit with Pat Harned, President of ECI. We took a deep dive into the 2023 Global Business Ethics Survey (GBES) revealed concerning trends in workplace ethics. The...more

The Volkov Law Group

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

The Volkov Law Group on

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

Society of Corporate Compliance and Ethics...

[Event] 11th Annual European Compliance & Ethics Institute - March 20th - 22nd, Amsterdam, Netherlands

In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more

Gray Reed

Boeing’s Board Agrees to $237.5 Million Settlement in Litigation Alleging Failure to Oversee Airplane Safety

Gray Reed on

The board of directors (“Board”) of The Boeing Company (“Boeing”) agreed to a staggering $237.5 million settlement of a lawsuit brought by stockholders on behalf of Boeing alleging that the Board and certain executive...more

The Volkov Law Group

Boeing Settles Shareholder Litigation and Agrees to Reforms (Part IV of IV)

The Volkov Law Group on

The crushing aftermath of the tragic 737 MAX scandal is disturbing at the least.  Innocent lives were lost because of Boeing’s culture misfires, poor leadership at the management and board level, and an arrogant disregard for...more

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

The Volkov Law Group on

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

Latham & Watkins LLP

White Collar & Compliance Academy 2021 - Die Zukunft

Latham & Watkins LLP on

Compliance & Investigations im Jahr 2025 - „Wirksame Compliance erfordert ganzheitliche Ansätze.“ Was ist für die Themen „Compliance & Investigations“ im Jahr 2025 zu erwarten? Fünf Thesen von Prof. Dr. Thomas Grützner...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

The Volkov Law Group on

Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

The Volkov Law Group

Lessons Learned from the Goldman Sachs FCPA Enforcement Settlement (Part III of III)

The Volkov Law Group on

Goldman Sachs has a new leadership role – unfortunately, it is for corruption.  It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors.  Instead, Goldman...more

The Volkov Law Group

The State of Corporate Board Performance and Accountability (Part I of IV)

The Volkov Law Group on

It is perhaps fitting that we are coming up on the one-year anniversary of the Business Roundtable’s Restatement of Corporate Purposes, which was signed by 181 corporate leaders and widely-praised for its expansion of...more

The Volkov Law Group

Admit It – Your Compliance Program is Not Really “Effective”

The Volkov Law Group on

Chief compliance officers are heroes.  They labor every day to advance a company’s ethics and compliance program without much recognition, with few resources, and with well-known gaps in their programs....more

The Volkov Law Group

Incident Data and Intra-Company Cooperation

The Volkov Law Group on

The Justice Department “listens and learns” from companies and compliance practitioners.  As part of every enforcement action, DOJ prosecutors review and assess compliance programs in accordance with the standards explained...more

Thomas Fox - Compliance Evangelist

Farewell to Harrison Dillard and a CCO Using Empathy

As a Chief Compliance Officer (CCO) one of the most powerful tools you have is persuasion. Jenny O’Brien, CCO at UnitedHealthcare, has talked about the techniques that a CCO can use to influence decision making in a company...more

The Volkov Law Group

What Does “Business Ethics” Mean?

The Volkov Law Group on

Without belaboring all the feel good and esoteric discussion surrounding societal ethics and applying these concepts to business ethics, I would suggest that we focus on the term “business ethics” by focusing on the concept...more

Thomas Fox - Compliance Evangelist

Preventing White Collar Crime

I conclude my short exploration of the recent set of articles in the Harvard Business Review (HBR) White Collar crime special section. Today, I want to look at an article by Mary Jo white, entitled “What I’ve Learned About...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Creeping Man and Risk Management by the Board

CCO reporting to the Audit/Compliance Committee must be structured carefully to promote ethics and compliance. Here are five best practices to help guide the reporting....more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Blanched Soldier-Learning to Ask For Help

Many compliance professionals in the corporate world work long and it is hard to rise to the senior management level in their organizations. It takes SME, hard work and sometime propitious good fortune to get to the C-Suite...more

Thomas Fox - Compliance Evangelist

Farewell to Rip Torn and Hello to Compliance Incentives

In the recently released Evaluation of Corporate Compliance Programs, 2019 Guidance by the Department of Justice, incentives are specifically identified in the section under “is your program effectively implemented?” The 2019...more

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