As I get older, I try and convince myself I am getting wiser.  But I know that is not right.  Maybe a better way to say it is I am better at guessing.  Some like to call that educated guessing.  Talk about an oxymoron. I can never understand why companies don’t pay more attention to board governance.  There is the usual rush around a corporate...

The title for this posting is a little ambiguous.  What is the “cost” of compliance?  Is it the cost of implementing an “effective” compliance program?  Or is the “cost” to the company of an “ineffective” compliance program.  Let’s just say it is both. I often criticize the compliance profession for relying on the “negative” message around compliance – “if you do not comply, then the...

I was never a big fan of the Reagan Administration’ solution to America’s drug problem – Just Say No.  The phrase was a simple solution to a more complex problem, one that people now recognize as a health problem rather than a question of free will. My concerns with the “Just Say No” strategy do not extend to foreign bribery.  In fact, I know several...

When it comes to compliance, the best investment a company can make is to create and promote an ethical culture.  Dollar for dollar, communicating this message is the money well spent. A CEO has to commit time and effort to the program.  If the CEO does not want to commit, the job will be much harder.  A CEO who believes in the message of ethics...

The GM scandal is unfolding and provides important reminders for everyone involved in compliance and how to respond to a corporate scandal. GM faces a significant set of challenges.  A faulty ignition device has been linked to a number of crashes resulting in over 10 deaths.  GM decided not to recall automobiles to fix the faulty ignition. GM is now the focus of a Justice...

“Get your facts first, then you can distort them as you please” – Mark Twain Corporate boards have to be more involved and informed.  I know this sounds like a profound grasp of the obvious but corporate governance needs to move forward.  This is not rocket science – we have all faced difficult issues and challenges.  Corporate governance reform is not one of those types...

Chief Compliance Officers always are asked to do more with less.  It is a simple and overused phrase, usually promoted by corporate bean counters looking for ways to justify decisions that serve their own financial interests. There has to be a better way to coin this phrase in the compliance context.  CCOs are innovative and creative professionals.  They like to embrace the concept of “leveraging”...

If you want to do the right thing in the ethics and compliance world, follow Donna Boehme (on Twitter (here)), in her regular columns in Corporate Counsel and other publications, and at her website (here)). Donna knows what she is talking about.  She consistently challenges the idea of “tone-at-the-top,” when it’s talk, not walk (here).  She explains that the concept is overused because it begs...

Chief Compliance Officers act with integrity.  When it comes to their work, they know when an organization is committed to compliance.  They also know when ethics and compliance is “window dressing.” The recent announcement that JP Morgan’s CCO is leaving after one year is a very telling development.  When the CCO picks up and leaves, it usually reflects one thing – the organization is not...