Author: Michael Volkov

5 Telltale Signs of a Weak Corporate Culture

We all know it when we see it – a company with a weak corporate culture of ethics and compliance. Many companies claim they have an ethical culture but few really do. With increasing emphasis and understanding of the tangible benefits of an ethical culture, companies are striving to achieve such a goal. Unfortunately, there is no single solution to companies that want to establish...

Two Steps Forward, One Step Back – Mixed Bag of Compliance Progress

Companies are embracing the value of compliance and ethics. Interestingly, companies are implementing robust compliance programs, and enhancing such programs with a focus on ethical business values and decision-making. These are welcome signs of improvement and underscore the continued growth of compliance and ethics strategies as a basic part of corporate governance frameworks. A recent survey conducted by Ethisphere and Convercent, 2017 Ethics and Compliance...

The Challenge of Auditing and Monitoring Your Distributors

Whether you are in the high-tech industry and managing your channel partners (i.e. third-party distribution network), the pharmaceutical and medical device industry managing a complex network of distributors and sub-distributors, or any other industry relying on third-party distributors, chief compliance officers face a number of challenges managing and mitigating risks. To state the obvious, a company relying on distributors, by definition, has less control over...

Blockchain and the Future of Compliance

At a recent conference of the high-tech industry, an IBM representative provided a fascinating presentation on blockchain technology and the application to compliance programs. It was a fascinating presentation. Maybe I cam coming to the party relatively late, but blockchain technology, as it gain acceptance in the marketplace, could have a real significant impact on compliance functions. Aside from compliance applications, blockchain could have significant...

The EU’s New General Data Privacy Regulation (GDPR) – Global Companies New Compliance Test

Global companies face a daunting array of risks – anti-corruption, trade compliance, antitrust, and money laundering are just a few. The European Union, however, has escalated the data privacy issue right into the corporate boardroom. Global companies will have to devote significant time and resources to building appropriate data privacy compliance programs. The EU’s new General Data Privacy Regulation (or GDPR), which is effective May...

CCOs: The Importance of Documenting a Compliance Program

Tom Fox (here) frequently reminds every one of the importance of documentation to the integrity of a compliance program. A compliance program is only as good as the documents show. This principle is especially critical when a company has to respond to a regulatory inquiry or to an enforcement action. As we anticipate the testimony of former FBI Director James Comey in our current national...

“The Future is Now” — Compliance and Technology

This posting is not a “pie in the sky” outline of compliance in the future, when technology works seamlessly with compliance functions. My focus today is on what is happening now in the compliance world when it comes to technology. Unfortunately, this is not a column that is limited to compliance. I am repeatedly struck by the failure of Fortune 500 companies to embrace and...

A CCO’s Challenge: How to Convince a CEO to Embrace Compliance

A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he is facing. All too often, I hear of CCOs who join a company based on numerous promises and representations by the CEO, the board and senior managers about the importance of...

Ensuring Compliance with Controls

Let’s start with some basics – a public company is required to implement a set of internal controls. A compliance program is a critical part of a company’s internal controls. A company’s compliance program is only as effective as its board, executives, managers and employees adhere to the compliance policies and procedures. If a company’s constituents do not comply with the compliance program and policies,...

Promoting an Ethical Culture — Actions Not Just Words

With an increasing focus on the value of an ethical culture, I have been reading more about chief ethics officers, the separation of ethics and compliance, and the traveling ethics officer who meets with employees to discuss ethics. Forgive me for being a contrarian but everyone is missing the point about an ethical culture. A company does not instill and promote an ethical culture by...