This is a posting that I have wanted to write since the GM scandal occurred. I have to start with a rhetorical question – Would the GM debacle have occurred if GM had an independent and empowered Chief Ethics and Compliance Officer? The answer to this is not as easy as you think. Having an empowered CECO does not necessarily mean that all legal violations,...
Continuing with my list theme for the week, it is important to remind everyone that a culture of compliance begins with the board of directors, filters to the CEO who commits to promoting ethics and compliance in the company, and finishes with a fabric of ethics and compliance that is built on trust and integrity. I recognize I have said more than a mouthful but...
In the era of global antitrust cartel enforcement, antitrust practitioners often scratch their collective heads and ask why is antitrust compliance so ignored by government enforcement agencies. Instead of promoting antitrust compliance programs by offering real and meaningful incentives, antitrust enforcement agencies offer no carrots to companies to enhance their antitrust compliance program. Antitrust enforcement leaders often promote a simplistic argument – if a company...
Chief Compliance Officers are the rising professional stars in the corporate employment landscape (along with IT professionals who have practical perspectives). The profession is at an important test – where will the profession go from here and what steps do CCOs need to take to prepare for these challenges? I always say that CCOs are a confident group of people. They are committed to not...
In this Internet-age of ADHD and simplistic thinking, I thought I would contribute this week by putting together some lists of common themes in the ethics and compliance world. Unfortunately, we are all addicted to quick analysis, rapid descriptions, and targeted thinking. It is one of the downsides of our new information age. In fairness, I have to admit there are significant upsides to our...
Like Tinkers to Evers to Chance completing a double play, compliance programs need to maintain important links among three key elements – its complaint system, the handling of such complaints, and the publicized resolution of such complaints to encourage its Speak Up culture. Complaint Reporting Channels: Many companies have more than one avenue for officers, managers and employees to complain. That is a good thing....
You have to admire the vigilance and dedication of prosecutors and law enforcement investigators who fight Medicare fraud. There is no question that they have ramped up enforcement and promoted a strong message of deterrence. Consider the nature of the problem. The FBI estimates that between five and ten percent of all healthcare expenditures (government and private) are fraudulent. Medicare suffers huge annual losses from...
The Volkov Law Group is offering a great opportunity for experienced attorneys seeking a position with a nationally-recognized boutique law firm. A leader in anti-corruption compliance and defense, the Volkov Law Group offers an innovative work environment with virtual offices on both east and west coasts. The Firm specializes in ethics and compliance services, including anti-corruption, trade compliance and AML services, as well as white...
I am pleased to announce my affiliation with NAVEX Global, and the issuance of a white paper – A Holistic Approach to Global Anti-Corruption Compliance, which is available here. There is no other company (or brand) which carries as much weight in the compliance field – NAVEX Global is a true leader, committed to professional technology solutions for ethics and compliance. NAVEX is the gold...
One of the many challenges in the compliance profession centers on coordination and integration. There are plenty of compliance experts who can describe a perfect world – how to design a specific program and procedures to implement the program. Vendors are ready to line up at a chief compliance officer’s door and sell them products which will carry out a specific program. The challenge for...
