As CCOs become a key player in the corporate governance world, ethics and compliance leaders are developing principles to be used by compliance pofessionals. It is a natural process that reflects the growing “professionalization” of the compliance profession. It would be helpful for compliance officers to develop their own code of conduct, i.e. a set of general principles to help guide compliance professionals in their...
July 8, 2014, 12 Noon EST SIGN UP HERE Companies have designed and implemented anti-corruption compliance programs. An important element of an effective compliance program is monitoring and auditing the program to identify issues for improvement. Working in collaboration with the Internal Auditor, Chief Compliance Officers have to rely on tailored monitoring and auditing procedures to identify issues for review to ensure improvement of a...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for an interesting post on the GM scandal. Lauren’s bio is here and she can be reached at lconnell@volkovlaw.com. 44 recalls. 13 deaths. 20 million vehicles. 9 years. 3 Congressional appearances. These five numbers tell a terrible and tragic story you probably recognize as the GM ignition switch recall debacle. This is a...
As Chief Compliance Officers rise in the corporate hierarchy, they will become the focus of more enforcement actions. This increased focus on prosecution of CCOs could have a chilling effect on their performance and the rapidly increasing pool of talent seeking to enter the compliance profession. As always, the devil is in the details. Just because a CCO has the title CCO, does not mean...
When reading about corporate governance, it is hard not to get frustrated. So-called “experts” in the field provide little practical advice but are filled with platitudes that apply to corporate boards, senior management and governance. Acronyms are bandied about as a special language is only understood by the great thinkers in the GRC discipline. Everyone needs to take a step back, agree on some basic...
As the old adage goes, appearances can be deceiving. Sometimes when you peel back the layers on an issue, you find out that everyone, even the Justice Department, can engage in “spin.” With trumpets and fanfare, the Department of Justice announced the Credit Suisse guilty plea for criminal tax evasion. Puff pieces were circulating in the press announcing the $2.6 billion criminal fine paid by...
With all the attention on ethics and compliance, it is interesting to take account of the vocabulary — terms like “culture, governance, access, processes, diligence, independence, and empowerment” are all bandied about. One term that is even more critical and frequently ignored is “accountability.” Ethics and compliance is so frequently tied to joint concepts, it is a gestalt that has little room for individual considerations...
“There is nothing more difficult to take in hand, more perilous to conduct, or more uncertain in its success, than to take the lead in the introduction of a new order of things.” — Niccolo Machiavelli, The Prince (1532) We all have been following the “turn around” projects at some of the big companies — Walmart, Morgan Stanley, SNC-Lavalin, just to name a few. Changing a corporate...
I am pleased to announce that I will be hosting the first day of an exciting anti-corruption conference sponsored by American Leaders on September 10 and 11, 2014, in Washington, D.C.: Enhancing FCPA and Anti-Corruption Compliance for Life Sciences Conference. The Sign Up for the Conference is Here. Also, if you use the Promotional Code VOLK25, you will receive a 25 percent discount on...
I am pleased to announce that I will be hosting the first day of an exciting anti-corruption conference sponsored by American Leaders on September 10 and 11, 2014, in Washington, D.C.: Enhancing Anti-Corruption Compliance for Life Sciences Conference. The Sign Up for the Conference is Here. Also, if you use the Promotional Code VOLK25, you will receive a 25 percent discount on the conference...
