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DOJ’s compliance counsel, Hui Chen, pronounced this year as the compliance year of third party due diligence. This has been a good year for compliance, but I would not characterize this year as limited to third party due diligence. I am not sure why Ms. Chen focused on third
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I always use the “Streetcar Named Desire” line to describe the challenges a Chief Compliance Officer faces – CCOs depend on the kindness of strangers. It is a little bit of an exaggeration but bear with me. CCOs are not superheroes and cannot by themselves ensure an effective ethics and compliance
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Individual commitment to a group effort - that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these
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These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the independence of the CCO from the legal function, the reporting obligations and
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This week I am devoting five postings to defining the “new” model of ethics and compliance – Compliance 2.0. If you read through compliance writings, blogs, articles, white papers, and other sources, you will see the term “Compliance 2.0” bandied about. It is a term that has yet to
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A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success of a compliance program depends on acceptance and embrace by the business.
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Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us with this posting. Lauren can be reached at lconnell@volkovlaw.com. Her profile is here. FCPA practitioners are familiar with the term “public international organization” as included in the definition of “foreign official” for FCPA liability purposes but do
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Compliance has to continuously improve – as companies innovate, so do critical foundation functions like compliance. The forces of change on corporate governance and compliance were unleashed years ago. There is no way to put the genie back in the bottle – the wave is continuing to grow and so long as
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Your CEO is either on board for compliance, or he/she is not. There is no half-way mark here, no way to deceive or soft-shoe your way through the compliance requirement. Yet it is common to see a CEO who is not committed and a Chief Compliance Officer
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Some things are easy to define by negative inferences. Corporate ethics or business ethics are not the same as legal ethics. Business ethics are not the same as our philosophy ethics – Aristotle and all of the classic philosophers were not operating in a corporate context. Some things require a positive
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Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and compliance can pose serious challenges for CCOs seeking to implement an effective ethics and compliance
Events
Webinar: Compliance 2.0 -- A New Model for Ethics and Compliance Programs Tuesday, November 10, 2015, 12 Noon EST Register Here In the last year, ethics and compliance leaders have been describing a new model for ethics and compliance programs, referring to it as "Compliance 2.0." For