As compliance programs (and the profession) continue to mature, there is growing interest in the need for measurement, monitoring and auditing of compliance programs.  This is a natural evolution in the lifecycle of a compliance program. Once a CCO has operationalized a company’s compliance program, the next challenge logically is to design strategies to ensure proper operation.   The elements of an effective compliance program include...

I was honored to be named as a Top Thought Leader for 2019 by Trust Across America. More importantly, I am privileged to share this honor with 91 global professionals from a broad spectrum of professionals involved in integrity and trust, leadership, culture, compliance and ethics, reputation and risk management, governance, communications, employee engagement, sales and customer service.  The Announcement in TRUST Magazine’s Winter 2019...

Managing your third-party risks requires a wide-angle view of your third parties.  What do I mean by that? Companies are hyper-focused on identifying risks during the onboarding process, the use of automated platforms to organize and conduct such screening, and continuous monitoring through an automated platform.  Such a perspective, however, is far too narrow in scope and scale.  Too many third-party risk management strategies ignore...

In a stark message, Justice Department prosecutors have brought the first criminal case for anti-money laundering violations against a broker-dealer.  Central States Capital Markets, LLC (Central States) agreed to pay a $400,000 penalty and entered into a deferred prosecution agreement (DPA) with the US Attorney’s Office for the Southern District of New York for violating the bank Secrecy Act. As set forth in the court...

There is no question that corporate leaders, senior executives, legal and compliance staff, and internal auditors recognize the value of an ethical corporate culture.  It is the latest “fad” in corporate governance, and it is a welcome development.  I have written extensively on this important trend and the value of a company’s culture of ethics and compliance. CEOs and corporate executives, however, have embraced this...

I had the honor of appearing with Julie DiMauro, a Regulatory Intelligence Expert, at Thomson Reuters Legal, in her regular videocast on important legal and regulatory issues. In our discussion, we review FCPA enforcement and compliance trends. The video is available HERE. Julie is a thought-leader in the regulatory and legal space. She is the Regulatory Intelligence Expert at Thomason Reuters Legal, and is a...

Companies involved in the export and import of defense products and services face significant risks surrounding compliance with the International Traffic in Arms (ITAR) statute and regulations.  The US State Department’s Directorate of Defense Control (DDTC) tightly regulates the defense industry and aggressively enforces ITAR rules and regulations. In this episode, Michael Volkov interviews Colleen Hurson, Senior Counsel, at The Volkov Law Group, who specializes...

Over the last couple weeks, I was recently featured in two videos highlighting the importance of building ethical corporate cultures. You can find them published on this online compliance community called Compliance Next. Here are links to two videos I recorded on the importance of corporate culture:Part 1 — HerePart 2 — Here In these videos, I consider why people slow down at school crossings. Is it to...

Businesses understand that their trade secrets are valuable assets.  However, businesses fail to understand how vulnerable their trade secrets are to misappropriation and straight-out theft. The US Justice Department has been beefing up its enforcement in this area, relying on new and existing prosecution and investigation tools. Companies have to act with vigilance by protecting their confidential and sensitive trade secrets, and aggressively prosecuting civil...

A fundamental requirement for an effective ethics and compliance program is that it is supported by “adequate resources.”  This does not mean a bare minimum requirement; nor is this requirement satisfied by flat-lining a compliance department’s annual budget.  Someone is not getting the message straight – a compliance program has to evolve – that does not mean that it has to suck up more resources...