I always use the “Streetcar Named Desire” line to describe the challenges a Chief Compliance Officer faces – CCOs depend on the kindness of strangers. It is a little bit of an exaggeration but bear with me. CCOs are not superheroes and cannot by themselves ensure an effective ethics and compliance program. An effective compliance program depends on a positive working relationship among the key...
Individual commitment to a group effort – that is what makes a team work, a company work, a society work, a civilization work.~ Vince Lombardi Like so many areas in life, a successful ethics and compliance program depends on teamwork. My last two postings, Parts 4 and 5, will highlight these essential partners – senior leadership and key compliance functions. In a company culture, teamwork...
These are heady days for Chief Compliance Officers. Over the last 20 years, the CCO has moved from the backwater of corporate offices to the front and center of the power structure. We now have debates over the independence of the CCO from the legal function, the reporting obligations and the relationship between the CCO and the board. There is no question that CCOs have...
Do the right thing. It will gratify some people and astonish the rest. – Mark Twain We all know the obvious – a CEO’s commitment to ethics and compliance is critical to the success of a compliance program. A CEo who stands up and speaks about the company’s culture of compliance is more than a breath of fresh air – it can be the lifeblood...
This week I am devoting five postings to defining the “new” model of ethics and compliance – Compliance 2.0. If you read through compliance writings, blogs, articles, white papers, and other sources, you will see the term “Compliance 2.0” bandied about. It is a term that has yet to be defined but is taking on a life of its own – a reflection perhaps of...
A Chief Compliance Officer who lacks working relationships with the business side of a company is like a day without sunshine. No matter how strong or finely tuned a compliance program is on paper – in practice, the success of a compliance program depends on acceptance and embrace by the business. I am always reminded of meeting a business manager in a company who told...
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Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us with this posting. Lauren can be reached at [email protected]. Her profile is here. FCPA practitioners are familiar with the term “public international organization” as included in the definition of “foreign official” for FCPA liability purposes but do we really know what the term means? Recent activity in an enforcement action for allegedly bribing a...
Compliance has to continuously improve – as companies innovate, so do critical foundation functions like compliance. The forces of change on corporate governance and compliance were unleashed years ago. There is no way to put the genie back in the bottle – the wave is continuing to grow and so long as corporate misconduct continues, corporate compliance will continue to reinvent itself in new ways....
The Justice Department’s reexamination of corporate incentives to disclose violations appears to be in reaction to the steady escalation of cooperation requirements. In response to these extra burdens, DOJ could be concerned that FCPA voluntary disclosures will dwindle. For years, voluntary disclosures have fueled DOJ’s FCPA enforcement program. In the context of a voluntary disclosure program, I have consistently written that DOJ has failed to...
