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...

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,...

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...

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...