Category: General

1 Oct, 2017

Podcast Episode 4 — Too Big To Fail, Too Big To Jail, DOJ’s Outsourcing of Criminal Investigations

The Department of Justice’s approach to criminal prosecution of corporations and individuals has evolved over the last 20 years. Beginning with the traditional model of building criminal cases, brick-by-brick, by investigating and prosecuting individuals, traditionally used to dismantle organized crime and drug trafficking/gang organizations, the Justice Department has now embraced a new model of enlisting corporations to conduct internal investigations, usually with the assistance of...

General

27 Sep, 2017

The Compliance Conundrum — Spending Money to Save Money

Chief compliance officers have to be honest with themselves. While I am optimistic about the growing importance of the compliance function, I remain concerned that CEOs and senior management are slowly strangling ethics and compliance programs through delays and denials of needed human and support resources to implement an effective ethics and compliance program. So, my question to CCOs is an important one – are...

General

26 Sep, 2017

The Five Most Important Issues for a CCO to Report to the Board

Chief compliance officers have to throw out their template for charts, diagrams and data that they use to report to the Audit/Compliance Committee and start over. Slick and colorful charts and diagrams are great but CCOs are ignoring the importance of an opportunity to educate and train the board on how to monitor and oversee a compliance program. So, let’s start over – what should...

General

25 Sep, 2017

Ethics and Compliance Controls – Different Means to the Same Objective

People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically enforced with no regard to purpose or results. I always get frustrated when people like to classify concepts as either black and white. People are uncomfortable with grey concepts,...

General

21 Sep, 2017

Subscribe to New Podcast Service

I am pleased to offer a free podcast service under the same title as the blog — Corruption, Crime and Compliance. We have added a button on the left slide of the blog to make subscribing easy. Here is link to Episode 2, which includes subscription buttons: Here We have released two episodes so far, and a third episode will be released on Sunday. Episode...

General

20 Sep, 2017

CEO Leadership – Honesty, Integrity, Listening and Empathy

At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional experience. I know there are lots of so-called “leadership experts” but I think much of leadership is intuitive and requires intelligence and interpersonal skills. I have worked...

General

19 Sep, 2017

No More Excuses: CCOs Have to Embrace Technology

It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move like a shark and constantly take into account new trends, new risks, and new business developments. CCOs who resist change are doomed to fail. This...

General

18 Sep, 2017

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...

General

15 Sep, 2017

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,...

General

13 Sep, 2017

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....