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Bringing a Compliance Program to Life: Connecting the Dots

Bringing a Compliance Program to Life: Connecting the Dots

A compliance program is an interdependent function that gains exponentially from coordination and cooperation with key functions.  CCOs have to be politicians and they have to develop effective interpersonal skills.  Without an ability to connect with other individuals in a company, a compliance program will suffer some real and substantial difficulties. Compliance officers have to develop a target list of coordinators and cooperators.  A CCO...

Episode 33 — Bitcoin, Cryptocurrencies and Compliance — Interview of Matt Stankiewicz

Episode 33 — Bitcoin, Cryptocurrencies and Compliance — Interview of Matt Stankiewicz

Cryptocurrencies, including Bitcoin, are exploding on the marketplace.  Cryptocurrencies are promising huge technological advances in our economy by relying on the new blockchain technology. Initial coin offerings raised $7 billion in capital last year, and this year ICOs are expected to raise over $20 billion in capital. Bitcoin and other established cryptocurrencies have increased in value.  Bitcoin reached a high of nearly $20,000 and is now trading just...

Internal Testing and Monitoring of a Compliance Program

Internal Testing and Monitoring of a Compliance Program

Compliance is a dynamic subject and a profession that “never sits still.”  Compliance professionals are always developing new ideas, strategies and approaches to solve problems, and increase efficiency and effectiveness.  It is a fast-growing profession that is quickly gaining greater acceptance as a critical member of the corporate governance team. As compliance gains a greater foothold, compliance professionals hopefully will gain access to increased resources. ...

Cryptocurrencies, Blockchain and Ponzi Schemes

Cryptocurrencies, Blockchain and Ponzi Schemes

When you read and learn about cryptocurrencies (e.g. Bitcoin, Ripple, Ethereum), there are some commentators, politicians and others who characterize cryptocurrencies as a “Ponzi” scheme.  Some countries have banned cryptocurrencies.  The issue of cryptocurrencies, like many other issues, is nuanced, and not so dogmatic.  As I like to say, there are benefits and there are risks.  Let’s address a number of the risks and lay...

The State of Whistleblowing

The State of Whistleblowing

We continue to read headlines of whistleblowers receiving large, sometimes, multi-million-dollar awards after successful prosecutions of companies for a variety of criminal and civil offenses.  From these headlines, we may be convinced that whistleblowers continue to grow in influence and achieving real results – the improvement of overall corporate performance.  I hate to burst the proverbial bubble, but it is difficult to reach such a...

Kinross Gold Mining FCPA Settlement: SEC Continues Internal Controls Focus

Kinross Gold Mining FCPA Settlement: SEC Continues Internal Controls Focus

The SEC continues to exercise its powerful enforcement tool – internal controls violations – in FCPA enforcement actions against public companies.  Kinross Gold Corporation is the latest company to enter into an FCPA settlement. Kinross agreed to pay $950,000 for inadequate internal controls and books and records violations centered on the activities of two mining companies Kinross acquired.  The SEC cited no evidence of any...

Episode 32 — Ten Steps to Prepare Your Company for Execution of a Search Warrant

Episode 32 — Ten Steps to Prepare Your Company for Execution of a Search Warrant

As part of the aggressive enforcement of white collar crime cases, federal  law enforcement officers are executing more search warrants at company offices.  Companies should plan in advance for such an event.  A company can learn valuable information about an ongoing investigation.  Just as important, company officials have to preserve and assert objections when federal agents conduct a search. In this episode, Michael Volkov outlines...

ECI’s New Business Ethics Survey Confirms Misconduct Rates Declining — But Retaliation Rates Increasing

ECI’s New Business Ethics Survey Confirms Misconduct Rates Declining — But Retaliation Rates Increasing

The Ethics and Compliance Initiative recently released the results of its global business ethics survey.  (Download Copy Here).  The last survey was conducted in 2017 and ECI’s survey provides important and valuable insights into corporate metrics and compliance, focusing on misconduct issues. The survey was conducted in late 2016 and 2017.  Thirteen countries were selected: Brazil, China, France, Germany, India, Italy, Japan, Mexico, Russia, South...

The State of Affairs: General Counsels and Chief Compliance Officers

The State of Affairs: General Counsels and Chief Compliance Officers

In the last few years, the tension between chief compliance officers and general counsels appears to have subsided.  The issue of separating CCOs from legal departments is not as important as it used to be.  Why? I would like to think that CCOs have gained independence, authority and line of sight across their organizations.  General counsels have acknowledged the importance of this change and accepted...