Tagged: CCO

The 5 Most Common AML Compliance Program Deficiencies

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance depends on: accurate and comprehensive risk assessments; pre-screening of customers through appropriate KYC programs; and audit and monitoring of transaction and customer activity. Despite the commitment and dedication of AML compliance professionals,...

Why is it So ($&#%*!) to Hard to Hire People in Compliance?

Maurice Gilbert, head of Conselium Executive Search (here), the leading  executive search firm for compliance professionals, has written a fascinating piece on the difficulty in hiring compliance professionals.   He was gracious enough to allow me to reprint it for CCC blog readers.  Maurice maintains the highly popular blog, Corporate Compliance Insights (here), and can be reached at maurice@conselium.com. As managing partner of an executive search...

The Time is Now to Amend the US Sentencing Guidelines on Corporate Ethics and Compliance Programs

We all know the importance of the sentencing guidelines and the impact the revisions, especially the 2010 amendments, have had on corporate governance and compliance. The history behind the sentencing guidelines tracks the rise of the compliance profession. The time is now for the Sentencing Commission to launch a further review of the guidelines to reflect the rapid changes in the compliance profession. The Sentencing...

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between getting a program implemented on paper and an “effective” anti-corruption compliance program. After all, when you boil it down, anti-corruption compliance is not as difficult a task as everyone thinks. Some programs are immature, some...

Mead Johnson: Baby Formula and Bribes

Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s illegal payments were intended to increase referrals by Chinese physicians and healthcare officials of Mead Johnson products, and obtain access to marketing and personal information about expectant and recent mothers. Over...

DOJ’s Disdain for “Paper” Compliance Programs

As we come to the close of the Obama Administration, the Justice Department will certainly be able to point to its record of aggressive white-collar enforcement in a variety of areas. One glaring claim omission from that list will be prosecution of senior executives tied to financial institutions responsible for the financial demise in the late 2000s. With that one big exception, across the board...

New E-Book: The Art of the Internal Investigation

I am pleased to announce the release of my new e-book — The Art of the Internal Investigation — by Corporate Compliance Insights.  To download a free copy, please visit here. Conducting an internal investigation in today’s risky enforcement environment requires numerous — if not continuous — judgement calls.  Stakes are high, and answers are never black-and-white. In this free eBook, Michael Volkov wields his...

Webinar: Managing Private Equity Corruption Risks

Date: Tuesday, August 11, 2015 Time: 12 Noon EST Sign Up Here Justice Department and SEC prosecutors are devoting greater attention to private equity FCPA enforcement. This coincides with increased SEC regulation and examination of the private equity industry. Private equity companies face significant corruption risks in global markets. From sovereign wealth funds to portfolio companies, private equity compliance officers have to design and implement...

Leveraging a Global Compliance Network

Multinational companies cannot employ and maintain a sufficient number of dedicated compliance staff to ensure the effectiveness of an ethics and compliance program. That is a reality and we all know that is true. Instead, global companies have to figure out ways to leverage other personnel from other functions to serve as some part of a global compliance functions. This regularly occurs with respect to...