We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...
Chief Compliance Officers carry a lot of weight on their shoulders. Some days, I am sure, they have trouble getting up and soldiering on to tackle the next challenge. As I always quip, no one congratulates the CCO on a job well done – instead, when something goes wrong, everyone looks to the CCO and asks, “What happened?” Like every leader, CCOs are charged with...
There is something in a name. More people in the compliance industry, when referring to third-party due diligence, are labeling it “Third Party Risk Management.” I like it because it is more accurate. Due diligence screening of existing or new third parties is just an initial step – it is not an end unto itself. Assuming that the third-party passes the due diligence review, there...
Lauren Connell from The Volkov Law Group rejoins us with a posting on the recent New England Patriots scandal relating to deflated footballs. Lauren can be reached at [email protected]. If only the New England Patriots had an Anti-Bribery and Anti-Corruption program, “Deflategate” might never have entered America’s vocabulary. The long-running saga re-entered the media this past week with the release of the internal investigation results, undertaken...
My colleague, Tom Fox, is a prolific writer. His talents extend from his new consulting firm, to his always interesting blog, and to his formal written volumes of work. Tom is a major contributor to the compliance profession. Everyone can always learn something from Tom, no matter what you level of experience. Compliance Week just released Tom’s new hardbound book — Doing Compliance: How to Design, Create,...
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The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources. In the anti-corruption and sanctions compliance arenas, technology is an important tool, especially for third-party risk management and knowing who your business partners and customers are for sanctions compliance. AML and Bank Secrecy Act compliance heavily depends on...
Everyone likes to talk. For most people, it is hard to listen. Chief Compliance Officers have to be proficient at both, especially listening. I have often criticized CCOs who engage in Happy Talk when reporting their boards. It is a practice that reveals much about the CCO, the company’s ethics and compliance program, and the overall corporate culture. CCOs committed to honest board reporting reflect...
As the old saying goes, “don’t break your arm patting yourself on your back.” Everyone is pretty happy about their due diligence systems for screening third parties. I understand how they feel but there is still a long way to go. It is one thing to screen a third-party at the on boarding process; it is quite another to build out an entire due diligence...
I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating to FCPA enforcement. For years, the blockbuster OFAC sanctions enforcement cases have involved the financial industry. DOJ’s recent settlement with Schlumberger Oilfield for $232 million demonstrates DOJ’s commitment to...
