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In January 2018, the Department of Justice and the Securities and Exchange Commission announced criminal and civil charges against five KPMG and a Public Company Accounting Oversight Board employee arising from sharing of confidential audit inspection information by PCAOB employees with KPMG audit partners.  A sixth defendant, a KPMG official and former PCAOB employee plead guilty and agreed to cooperate with the government investigation.  The...

The ultimate success of a global ethics and compliance program often depends on the ability of local compliance officers to engage business operations in a specific country.  Of course, a global compliance program’s performance depends on cooperation and coordination at all levels, but in many cases, the ability of a local compliance officer to adopt creative and intelligence strategies to engage the business will establish...

Global companies face ever-increasing challenges when building and implementing global ethics and compliance programs.  From my vantage point, the set of challenges can be different depending on the industry.  Global regulated companies, such as pharmaceutical, medical device or financial institutions, face a different constellation of challenges than a global manufacturing company. Notwithstanding the risk and compliance differences among the specific industries, there are a number...

Webinar:  Making Your Board of Directors a Partner in Compliance Tuesday, February 20, 2018, 12 Noon EST Sign Up HERE Corporate boards set the tone for a company’s compliance program. Directors are responsible for overseeing and monitoring the company’s compliance program. Yet, corporate boards are not actively fulfilling their responsibilities. Chief compliance officers have to engage the company’s board, educate the board and secure a...

An effective ethics and compliance program depends on the Chief Compliance Officer’s authority, independence, and resources.  A company’s commitment to a compliance program requires money and employees – there is no question that words of support, organizational status in the C-Suite and a robust board reporting relationship are all important.  However, all those elements are important but, in the end, those principles mean relatively little...

Given the turbulent times we live in, it is refreshing when we hear a corporate leader explain the importance of trust as a corporate value.  Marc Benioff is the CEO at Salesforce who is aggressively pushing his company to meet a target revenue of $20 billion by 2022. More importantly, at a recent panel discussion at the Davos World Economic Meeting, Benioff gave a powerful...

The growth in ethics and compliance has had a dramatic impact on corporate actors, including the CEO, chief compliance officers, internal audit and chief financial officers.  The corporate board’s role in compliance continues to be deficient.  Corporate boards are in for a rude awakening — a new era of accountability for ethics and compliance is beginning. In this episode, Michael Volkov outlines the issues surrounding...

The compliance community is well aware of the risks in the C-Suite.  As you move up the corporate ladder, the level of risk from executive misconduct increases.  A rotten executive can quickly bring down a company, destroy its reputation, and raise a host of legal and reputational problems.  I have written numerous times on the importance of assessing C-Suite risks and building compliance and financial...

The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions.  (Here).  The NYDFS has filled a vacuum created by the failure of the federal government to act in this important area.  Congress has failed to enact any specific requirements; the federal government continues to rely on voluntary efforts and recommended standards.  As long as this vacuum continues, state regulators and...