Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting about ISO 37001 certification for your third parties.  Lauren can be reached at [email protected]. A lot of the focus on ISO 37001 so far has been on its value for companies considering certification as evidence of the quality of their own compliance program. With the SEC and DOJ both providing ample...

I like to repeat myself – attorneys are valuable for only two reasons: (1) attorney-client privilege; and (2) advice of counsel defense. I know I am not supposed to denigrate my profession but these are two important reasons, especially the attorney-client privilege. In the context of corporate internal investigations, the attorney-client privilege is an essential tool when conducting internal investigations involving serious issues. I am...

In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers. For most businesses, beneficial ownership is critical in two main legal contexts: sanctions compliance and FCPA risk. Both of these areas present significant risks to any US company conducting business overseas, regardless of what industry. Of course financial institutions face...

My final posting on this week’s ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger organizations have a separate ethics officer, and I am not suggesting to merge the positions. Every company should have a chief ethics officer, either as a separate function or as...

The challenge for corporations is to build practical approaches to business ethics and its specific corporate values. Business ethics as a field is all well and good but we need to start sharing specific and practical strategies to infuse our day-to-day conduct and advance our corporate performance. In doing so, I am not so limited nor naïve to suggest that the only measure is corporate...

Here is another profound grasp of the obvious – all companies need to make a profit. However, as companies begin to focus on long-term performance rather than short-term quarterly objectives, innovative leaders believe that profitability can be achieved without sacrificing social, environmental and moral considerations. To the contrary, the long-term success of a business may only thrive when it reflects the needs of its stakeholders...

This week I am examining in a four-part series the issue of business ethics in an attempt to provide practical approaches to business ethics to help build and promote a company’s culture. As more attention is paid to the importance of an ethical culture, I wanted to first offer some general observations. The field of business ethics is thick with definitions, moral arguments and theoretical...

To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar screen. In an FCPA enforcement week like no other, the Justice Department unveiled a total of seven charging documents (indictments or informations) for FCPA violations, five arising from the Rolls...

Gifts, meals, entertainment, travel, and hospitality expenses (GMETH) are high-risk for bribery but have not received the same attention lately as third party risk management. The advancing capabilities of software solutions in this area make now the time to take a fresh look at how to leverage technology to strengthen your program. Join me and MyComplianceOffice for a free webinar to review: Best Practices to...

The COSO framework contains important principles for structuring a global organization and its internal controls, including compliance policies and procedures. Compliance officers have to learn and use the COSO framework when communicating and convincing the CFO to embrace a new world with both compliance and financial controls within an effective governance framework. Global companies are recognizing (sometimes slowly) that management silos in a company prevent...