Tom Fox (here) frequently reminds every one of the importance of documentation to the integrity of a compliance program. A compliance program is only as good as the documents show. This principle is especially critical when a company has to respond to a regulatory inquiry or to an enforcement action. As we anticipate the testimony of former FBI Director James Comey in our current national...
This posting is not a “pie in the sky” outline of compliance in the future, when technology works seamlessly with compliance functions. My focus today is on what is happening now in the compliance world when it comes to technology. Unfortunately, this is not a column that is limited to compliance. I am repeatedly struck by the failure of Fortune 500 companies to embrace and...
A Chief Compliance Officer faces many challenges in designing and implementing an effective ethics and compliance program. If a CCO conducts appropriate due diligence before joining the company, he will know the challenges he is facing. All too often, I hear of CCOs who join a company based on numerous promises and representations by the CEO, the board and senior managers about the importance of...
Let’s start with some basics – a public company is required to implement a set of internal controls. A compliance program is a critical part of a company’s internal controls. A company’s compliance program is only as effective as its board, executives, managers and employees adhere to the compliance policies and procedures. If a company’s constituents do not comply with the compliance program and policies,...
With an increasing focus on the value of an ethical culture, I have been reading more about chief ethics officers, the separation of ethics and compliance, and the traveling ethics officer who meets with employees to discuss ethics. Forgive me for being a contrarian but everyone is missing the point about an ethical culture. A company does not instill and promote an ethical culture by...
The Health and Human Services Office of Inspector General (OIG) and the Health Care Compliance Association (HCCA) jointly released a resource guide on measuring the effectiveness of a health care organization’s compliance program. A copy of the guide can be downloaded here. The resource guide was the product of a roundtable meeting of OIG staff and compliance professionals on January 17, 2017. The roundtable focused...
Those who regularly read my blog have heard me often cite the need for the compliance profession to adopt professional standards. With the rise of the profession, and the expectations placed on the shoulders of compliance officers, the compliance profession has to develop and promote its own set of ethical standards. We have the benefit of many extraordinary and talented leaders in the compliance profession....
We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically. Transparency is a fundamental requirement for all citizens to monitor and regulate our government. When it comes to our criminal justice system, or the enforcement of our laws, we expect...
Deputy Attorney General Rosenstein’s appointment of Special Counsel Robert Mueller last week was a blockbuster development in the investigation of the administration. A copy of the DAG’s Order is here. Independent and Special Counsels A Special Counsel is different from Independent Counsels who investigated high-profile matters in the past. In the Watergate investigation, the Justice Department appointed Special Prosecutor Archibald Cox who was eventually dismissed...
Workplace Answers, a sponsor of Corruption, Crime & Compliance, is offering an online FCPA Quiz. It is fun to take and test your knowledge of the FCPA. The link to the test is here. While at the site, please take time to register with Workplace Answers, order a white paper, and consider your training program needs. Thank you again and have fun taking the quiz.
