A compliance program without CEO support is almost doomed to be ineffective. We all live by the standard of an “effective” ethics and compliance program. I am always reluctant to embrace a dogmatic expression but the support, and hands-on participation of a CEO, can be the difference between an effective and ineffective compliance program. A CEO not only has to embrace the importance of an...
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AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go (view episode here) – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the end of the pipe, and so on — you will get the picture. We all know about the...
One thing about maintaining a blog – you have nightmares (alright something a little less than that) about consistency in writing. All of us can be accused of having “evolving” positions, so maybe that is my rationalization. If you had to boil down the lessons of compliance, the reasons for its exponential growth in corporate governance, and the impact that compliance has had in corporate...
As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as regulators have paid more attention to the issue, and companies have recognized the importance of training as an effective means to communicate directly to managers and employees about ethics and compliance expectations. The FCPA...
Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true. Instead, global companies have to figure out ways to leverage other personnel from other functions to serve as some part of a global compliance functions. This regularly occurs with respect to...
You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to more important and difficult issues. I hate to be dogmatic but when it comes to this issue, there really is one obvious solution. Varying alternatives are less than...
We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...
FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML compliance. In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty...
It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not normally treat third-party payments as a high-risk activity. However, with increasing focus on illicit proceeds and tightening of AML/Terrorist Financing requirements, companies have to focus on this issue....
