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...
Webinar: Policy Management, Governance and Leveraging Your Culture of Compliance June 16, 2021, 2 PM EST SIGN UP HERE Companies today face increasing pressure to build effective ethics and compliance programs as part of an overall governance structure. Investors, activists and key stakeholders are pushing for transformative reforms built around environmental, social and governance principles. An essential part of this initiative is a well-designed policy...
Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance program is a subset of a company’s internal controls. So, all this is well and good. But it appears that a number of companies have been getting into trouble because they...
Effective Management of Employee Reporting Systems August 12, 2020, Noon EST Sign Up Here. The compliance and ethics hotline represents one of the most integral tools available to a high-functioning Compliance Department. Companies that implement and properly manage their reporting hotlines create a more positive and robust organizational culture. In this webinar, Michael Volkov explains how to effectively manage your employee reporting system to create...
A chief compliance officer can get overwhelmed with responsibilities and initiatives. CCOs have a never-ending to-do list – once an initiative is finished, the CCO has to jump to another “priority.” CCOs are responsible for operationalizing the company’s compliance program. The CCO’s success depends on the cooperation of related functions – procurement, legal, human resources, security, finance, internal audit, and information technology. While there has...
No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April 5, 2017, the scheduled expiration date. Blanco stated in a speech given at the annual White Collar Crime Conference: Before I conclude, I would be remiss if I did not...
CCOs face many challenges in their jobs. One area that is difficult but usually can be solved with common sense is where to draw the line on attorney-client privilege issues. As a practicing attorney, I can attest to the importance of the attorney-client privilege. It is a principle that is critical to the functioning of a corporation or any other organization. Communications for the purpose...
DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate. Under the FCPA Pilot Program, a company can earn up to a 50 percent reduction from the bottom of the applicable range for calculation of a criminal fine. DOJ also noted the possibility of a declination with...
I was honored to participate in a brief podcast conducted by the MIS Training Institute, the International Leader in Audit and Security Training. The link to the podcast is here.
Perhaps the most positive and important aspect of the FCPA Pilot Program was the announcement of forward-looking and innovative remediation requirements for corporate compliance programs. As an aside, DOJ’s FCPA Pilot Program was a disappointment and failed to deliver meaningful incentives for companies to self-disclose FCPA violations to the Justice Department. The difference between 25, 50 and 75 percent from the bottom of the sentencing...
