A chief compliance officer can only succeed with the support of other important compliance partners.  Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the kindness of strangers.”  This observation, while dramatic in license, applies to the place of the compliance officer in the corporate governance world. A key partner for compliance...

Research has consistently demonstrated that an ethical corporate culture results in increased profits and sustainable growth.  Companies with a positive culture have lower rates of employee misconduct, increased employee productivity, and lower employee turnover.  All of these factors lead to higher growth rates, improved employee morale, and a reduced risk of misconduct and government investigation. This basic premise holds true: when ethical values are embedded in a company’s...

The fundamental principle of SEC’s market regulation is the power of sunshine, transparency and disclosure.  In other words, the SEC seeks to ensure that companies disclose important information to the public so that securities markets operate efficiently.  Whether the SEC has appropriately applied this principle in regulating the securities industry is a debate for another day.  The SEC, however, has used this policy goal to...

We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.”  One of the unfortunate consequences is that otherwise important issues often fade in competition with these ever-pervasive scandals.  Please do not misunderstand me – the...

Tom Fox has been called the “Compliance Evangelist.”  Whatever title may be given to Tom, one thing is for sure – Tom is a steady force, providing practical advice to advance the compliance function. To that end, Tom’s latest contribution is a new tome – The Complete Compliance Handbook: A Guide to Operationalizing Your Compliance Program.  I recently received my autographed copy of Tom’s new...

Michael Volkov Quoted by ABC News:  Michael Avenatti casts himself as anti-Trump avenger, May 16, 2018 HERE The inspector general of the Treasury Department is now investigating possible leaks of Suspicious Activity Reports, or SARs, from Cohen’s financial institutions. “Suspicious activity reports are confidential. They’re not allowed to be leaked,” said Michael Volkov, a white-collar defense lawyer who spent seventeen years as a federal prosecutor...

Tom Fox is a thought leader for the ethics and compliance profession.  He is a prolific writer who has produced a steady body of work — podcasts, books, blogs, articles — to advance the compliance function.  He is knowledgeable, practical and insightful on how to implement and maintain an effective compliance program. Tom has just released a new and important book — The Complete Compliance Handbook. ...

Corporate commitment to speak up cultures is suffering.  The Ethics and Compliance Initiative’s recent Global National Business Ethics Survey (available HERE) contained a critical finding – corporate instances of retaliation against employee for raising concerns doubled in the last five years. In the 2013 survey, 22 percent of respondents reported instances of retaliation against employees.  This number increased to an astounding 44 percent of respondents...

As parents we all have been through the following scenario – we encourage our children to communicate and voice their concerns and to learn to articulate, reason and understand perspectives.  So, our kids start to speak up and we listen, patiently, but at some point, our patience wears thin, and we are not as interested or willing to listen.  Our children begin to question our...

We all know the saying – A fish rots from the head.  Sometimes a clear and simple statement says it all.  The Volkswagen diesel emissions cheating scandal is yet another example of C-Suite, even CEO, misconduct. The Justice Department recently announced the criminal indictment for former Volkswagen CEO, Martin Winterkorn, age 70, for conspiracy and wire fraud for Volkswagen’s scheme to defeat U.S. diesel vehicle...