Empowering Compliance Officers

You may also like...

8 Responses

  1. Anonymous says:

    Could not agree more although I recently saw a company establish a compliance council that had representatives of all business units within the organisation. What they have created is their own UN council of 26 people. This structure has taken the concept to the extreme to the extent the intent of the council has been forgotten from a compliance standpoint and is now in place so management can pat themselves on the back and demonstrate they have a compliance function and it represents the business. The aforementioned council is expects to report, review, discuss and guide the company through its compliance programme, all it will do is bog it down, miss guide it and air the companies confidential dirty laundry to a large group of non-lawyers. At this point, I will comment, this companies model has no lawyers either on the council or within the compliance unit. In addition, all 26 persons on the council have no formal or experience in compliance. Most are either HR managers, finance or the business heads themselves, who are more than likely unwilling to launder their dirt in such a big group. I am surprised companies still simply just don't get it.

  2. Anonymous says:

    Could not agree more although I recently saw a company establish a compliance council that had representatives of all business units within the organisation. What they have created is their own UN council of 26 people. This structure has taken the concept to the extreme to the extent the intent of the council has been forgotten from a compliance standpoint and is now in place so management can pat themselves on the back and demonstrate they have a compliance function and it represents the business. The aforementioned council is expects to report, review, discuss and guide the company through its compliance programme, all it will do is bog it down, miss guide it and air the companies confidential dirty laundry to a large group of non-lawyers. At this point, I will comment, this companies model has no lawyers either on the council or within the compliance unit. In addition, all 26 persons on the council have no formal or experience in compliance. Most are either HR managers, finance or the business heads themselves, who are more than likely unwilling to launder their dirt in such a big group. I am surprised companies still simply just don't get it.

  3. michael volkov says:

    Sounds like a crazy set up — you are exactly on point. Companies just do not get it.

  4. michael volkov says:

    Sounds like a crazy set up — you are exactly on point. Companies just do not get it.

  5. Anonymous says:

    Unfortunately Michael, I voiced my opinion on this and other issues, recently escorted from the building. No anybody who needs a good compliance counsel who calls it as it is?

  6. Anonymous says:

    Unfortunately Michael, I voiced my opinion on this and other issues, recently escorted from the building. No anybody who needs a good compliance counsel who calls it as it is?

  7. Anonymous says:

    Having gone through a similar situation, I was told by my supervisor, a fellow learned colleague, that an agent agreement intended to procure government approvals was simply a "bad business decision". Has the bad business decision ever got up as a defense? We wouldn't know because no one has been so stupid to run that chest nut! Or have they? In addition, the same astute counsel pointed out that emails explicitly describing the conduct underlying the corrupt intent were inadmissible under the hearsay rule. Bright spark had obviously forgotten exceptions to the Hearsay rule, specifically, the business purpose test. Desperate!

  8. Anonymous says:

    Having gone through a similar situation, I was told by my supervisor, a fellow learned colleague, that an agent agreement intended to procure government approvals was simply a "bad business decision". Has the bad business decision ever got up as a defense? We wouldn't know because no one has been so stupid to run that chest nut! Or have they? In addition, the same astute counsel pointed out that emails explicitly describing the conduct underlying the corrupt intent were inadmissible under the hearsay rule. Bright spark had obviously forgotten exceptions to the Hearsay rule, specifically, the business purpose test. Desperate!