One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations.  To focus on the latter, I have met some amazing CEOs, Chief Compliance Officers, and other senior executives.  To be candid, I have also met some not-so-great CEOs and senior executives.  To...

I always enjoy pulling out the crystal ball and looking forward with due consideration of last year’s trends.  It is a perspective that gives us all the opportunity  to identify important trends and to set an agenda for the next year – 2023. The compliance profession continues to grow in overall importance in the corporate governance landscape. Corporate leaders that fail to appreciate this face...

We live in a challenging time — yes, another profound grasp of the obvious. From my narrow perspective, there are two significant trends occurring at the same time — people are angry and more willing to express their anger and frustration in situations, while others appear to be embracing empathy, kindness and increased concern for others.  I know this sounds circular but hear me out....

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on the Wells Fargo scandal.  Lauren can be reached at [email protected]. Wells Fargo’s cultural tone is not easily segregated between “top,” “middle” and “bottom.”  Despite the recent cross-selling scandal, in which the CFPB led an enforcement action whose fines total a whopping $185 million, Wells Fargo’s CEO John Stumpf reluctantly...

Like the Greek mythology character Sisyphus, Valeant Pharmaceutical is attempting to atone for its sins and turn its corporate culture around. I am not usually a cynic but when I see these transparent attempts to reverse a company’s culture, I have a degree of suspicion. In recent weeks, Valeant took the following steps: Hired a new CEO Joseph Papa Removed five directors from its board...

Compliance programs are required to create and manage case investigation systems to handle potential misconduct, investigate allegations of wrongdoing and then dispense discipline. Lessons learned from these investigations are valuable sources of information to improve compliance programs. Chief compliance officers play a critical role – either supervising the internal investigation system or coordinating with other functions in the organization to monitor internal investigations. Along the...

Forgive me for taking a step back to address an important challenge in creating a culture of compliance. I know this may sound obvious but in today’s “toxic” political environment it is important to point out some factors that may be beyond the influence of a corporate culture, its leadership and its compliance team. I have consistently ignored commenting on political issues and will continue...

Complacency in compliance is a cancer on a company’s culture. Woody Allen said it best in Annie Hall: A [compliance program] relationship, I think, is like a shark. You know? It has to constantly move forward or it dies. And I think what we got on our hands is a dead shark. Here is the video clip of the scene: here When a Chief Compliance...

Every company wants to create a culture of ethics. If the senior leadership ignores or downplays a culture of ethics, they have narrowed business opportunities for the company, its shareholders, and other stakeholders. A culture of ethics does not guarantee financial success, but it does add to the bottom line financial performance of a company. There are a number of necessary ingredients that have to...