Ethics and compliance programs face a rapidly approaching crossroads. Technology and data have created significant pressure on CCOs to harness innovation. This is a major opportunity for improvement but it also creates real risks. Chief compliance officers have to carefully tailor the transition to automated platforms and building of data management capabilities. The key to this effort is focus and simplicity. When CCOs overthink, they...
2019 was a big year for ethics and compliance. In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year. The federal government issued three important documents in 2019 – DOJ issued the Evaluation of Corporate Compliance Programs from the Criminal Division (here) and from the Antitrust Division (here),...
It has become appallingly obvious that our technology has exceeded our humanity. – Albert Einstein The human spirit must prevail over technology. – Albert Einstein Technology is nothing. What’s important is that you have faith in people, that they’re basically good and smart, and if you give them tools, they’ll do wonderful things with them. – Steve Jobs Believe it or not, these quotes concerning...
A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does not violate the law. A much simpler way to put it is – a company’s due diligence system is designed to negate any inference of intent to violate the FCPA. A due diligence...
