Tagged: adequate resources

The New Compliance Test: Do CCOs Have Senior Management Support and Resources to Innovate? (Part II of III)

The New Compliance Test: Do CCOs Have Senior Management Support and Resources to Innovate? (Part II of III)

This may be another in my series of profound grasps of the obvious – the compliance profession, research, technology and innovation are rapidly improving.  We all hear about innovative compliance approaches, new use of data analytics, application of behavioral sciences in program design and incentives, and sophisticated measurement programs.  As compliance tools become more affordable (e.g. blockchain), CCOs will have access to new technologies and...

DOJ’s Pilot Program – The Five Factors Designed to Nurture the Compliance Function

Perhaps the most positive and important aspect of the FCPA Pilot Program was the announcement of forward-looking and innovative remediation requirements for corporate compliance programs. As an aside, DOJ’s FCPA Pilot Program was a disappointment and failed to deliver meaningful incentives for companies to self-disclose FCPA violations to the Justice Department. The difference between 25, 50 and 75 percent from the bottom of the sentencing...