chief compliance officers Archives - Corruption, Crime & Compliance

2 Oct, 2022

Episode 249 — DOJ Issues New Corporate Enforcement Policy

The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records; appointment of independent compliance monitors and expanding review of responsible persons in an internal...

General

28 Jun, 2022

DOJ Compliance Program Certification Requirements (Part I of III)

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.” While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine...

General

26 Aug, 2021

Insights from Recent NAVEX Global and KPMG Surveys

Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry. Compliance professionals, as a general rule, are collaborative and willing to share information with each other. CCOs are an optimistic lot and enjoy sharing best practices, ideas and insights in order to further the ethics and...

General

2 Aug, 2021

When a CCO Fails to Speak Up

We often discuss the importance of a “Speak Up” culture. We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization. Chief Compliance Officers are a key messenger to spread the message of speaking up. But what happens when the CCO hesitates or even fails to speak up? After we all take a little truth serum,...

General

22 Dec, 2016

The Power of Honesty – A Candid Assessment of Your Compliance Program

The secret of life is honesty and fair dealing. If you can fake that, you’ve got it made. Groucho Marx We are all taught the importance of honesty. But there are very different aspects to this otherwise simple proposition. People are sometimes honest with each other, and sometimes they are not. Honesty, however, is a much harder concept when speaking to your self – you...

General

5 Oct, 2016

The Recalibration of Compliance: What is the Definition of Success?

We often hear a chorus of criticism relating to the compliance function. How do you define success? Some of this is the result of a political backlash. Chief compliance officers are the darlings in the corporate governance world, and there are forces aligned to challenge the importance of the compliance function. There are a number of internal political forces that want to undermine the growth...