Category: General

4 Signs of a Poor Relationship Between a CCO and the Board

Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to address internal operational issues. It is easy to “ignore” the importance of a positive relationship with the corporate board. A CCO who has a strong relationship with the company’s board...

Michael Volkov Interview with BvD’s Alistair King

I had the good fortune to spend time recently with Bureau van Dijk’s Alistair King for an interview. BvD recently posted the interview Here. BvD is a sponsor of this blog and a terrific compliance partner I have been impressed with BvD’s product offering – key tools in your third-party screening process that offer difficult to find information. BvD specializes in information on private companies,...

CCOs and the C-Suite

Let’s start out with something ironic – the C-Suite typically resists the need for ethics and compliance training, as well as other compliance controls, claiming that they know everything about ethics and compliance. Unfortunately, when a member or members of the C-Suite commit misconduct, the consequences can be devastating for the company. We all know high-profile instances of C-Suite misconduct involving bribery, fraud, and theft....

Slippery Slopes: “Broken Windows” and Employee Misconduct

Criminologists have debated for years the efficacy of the law enforcement strategy of “broken windows.” In simple terms, the theory suggests that minor infractions or petty crimes should be vigorously prosecuted in order to deter more serious crime. In addition, the theory suggests that a deteriorating environment (e.g. where broken windows are not repaired and allowed to increase), creates an environment where serious misconduct is...

The Emperor Has No [Compliance Program]

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make. It starts with a hypothetical – a CEO is supposed to introduce a company’s new code of conduct at a company event. Everyone attends – in person or virtually...

Live Webinar: How AI is Transforming Third Party Risk Management (via Live Stream)

Date: Wednesday, September 13, 2017 Time: 12–1pm ET; 5-6pm British Summer Time Registration Link I am excited to announce that I will be joining Exiger to discuss a topic many compliance professionals are actively engaged with – automating third party due diligence – and how advancements in technologies such as artificial intelligence (AI) can help your compliance program evolve. I encourage you to tune in and...

The Objective of Due Diligence: To Protect Your Culture

There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the marketplace with whitepapers, articles and information underscoring the importance of due diligence and advising on how to conduct effective due diligence. There is nothing wrong with the attention paid to...

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical trends and themes for US public reaction to corporate scandals and the political response to the scandal of the day. The US public is rightfully outraged over the Justice Department’s...

Compliance Missed Opportunities: CCOs and HR

A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.” CCOs are responsible for operationalizing the company’s compliance program. The CCO’s success depends on the cooperation of related functions – procurement, legal, human resources, security, finance, internal audit, and information technology. While there has...

Financial Controls and Contract Management Systems

Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the crafting and enforcement of such controls. A company faces serious harms, enforcement risks and collateral consequences from deficiencies in its financial controls. Sarbanes-Oxley requires public companies to...