Companies can become hyper-focused on anti-bribery compliance. It is easy to do – just look on the Internet, Twitter and Linked In. There are plenty of groups, hash tags, postings and discussions on anti-corruption issues. This focus on corruption reflects the reality of enforcement. But when it comes to misuse of funds, there is a significant, and oftentimes ignored risk – procurement kickbacks. Believe it...

A Chief Compliance Officer has a direct responsibility to promote the company’s business. That sounds like a controversial statement but it is not. Every officer and employee of a company has that responsibility. A CCO has a job – to design and implement an effective ethics and compliance program to detect and prevent Code of Conduct and legal violations. As the business grows, the CCO’s...

I never thought the day would come but it has – I have figured out a way to make Abbott and Costello relevant to the compliance profession. We all know their famous routine – “Who’s on First?” If you need a good laugh, check it out HERE. When it comes to lawyers and compliance professionals, the Abbott and Costello hilarious question is extremely relevant. Some...

A comprehensive approach to third party and vendor due diligence management is essential for any company conducting business globally.  A strong due diligence program’s purpose is two-fold: To guide your company, helping you make smart choices when it comes to international business partners, and To protect your company, building procedures and a legally-defensible documentary record that can protect you from an enforcement action (udner either...

“Action speaks louder than words but not nearly as often” – Mark Twain If you are too busy to read my posting, all I ask is that you read the Mark Twain quote and apply the message to creating an ethical culture. As I always say, Mark Twain would have been a star Chief Compliance Officer. He was an artist with words, and he used...

There is nothing more infuriating in the ethics and compliance world than a Chief Compliance Officer who relies on Happy Talk reports to senior managers and the Board. The CCO who engages in Happy Talk does a disservice to the profession and to themselves. So why are companies still not embedding real ethics and compliance programs? Too many are relying on paper programs that look...

A nickel ain’t worth a dime anymore. – Yogi Berra With all the hubbub about ethics and compliance, senior managers somehow are able to escape any focus or responsibility for compliance programs except in a managerial context. Senior managers need to be held accountable for their own personal ethics and compliance performance as senior executives with significant responsibilities. The GM debacle is a perfect example...

Compliance professionals love to bandy about the term “red flag.” It is a term with infinite meanings depending on the context. A red flag in a money-laundering context is different than a red flag in a corruption context. I like to say – not all red flags are created equal. Some red flags are more red than others – or in extreme cases, I use...