Everyone likes to give advice on the importance of tone-at-the-top. Like many things in life, it is easy to talk about but much more difficult to implement. There are lots of ways to describe or analyze the same issue. In the end the result has to be reached. To boil it down, tone-at-the-top requires leadership. That is pretty obvious. But, what kind of leadership? This...
We always bandy the phrase around of “people skills,” or the old trendy phrase of “emotional intelligence.” Hopefully, this posting can create some ideas around new approaches to these old concepts and trendy terminology. Compliance professionals need to develop strong interpersonal skills. It is one of several important personal skills and talents that are needed for a compliance officer to succeed. Maybe the point is...
As everyone knows, I am an advocate for promoting and maintaining a company’s culture of ethics and compliance (not compliance and ethics). The best investment a company can make is to create and maintain a positive commitment to an ethical culture. I often repeat myself (just ask my wife and kids), but a culture of ethics is far more important than well-designed and effective policies...
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...
A compliance program without CEO support is almost doomed to be ineffective. We all live by the standard of an “effective” ethics and compliance program. I am always reluctant to embrace a dogmatic expression but the support, and hands-on participation of a CEO, can be the difference between an effective and ineffective compliance program. A CEO not only has to embrace the importance of an...
We all know the importance of promoting a culture of compliance and ethics. The benefits of an ethical culture are substantial and worth every penny of investment in creating and promoting such a culture. We do not need to spend time justifying why an ethical culture is important to company financial success – it is critical for corporate sustainability and profitability. Not every company has...
I always enjoyed economics – understanding “rational” behavior and applying it to business situations can be very productive. Of course, there were many detractors who argued that economics is filled with assumptions that take the discipline away from reality, but I find those arguments unpersuasive. There has been a fair amount of research on corruption and the impact that bribery has on a functioning market....
If you can’t explain it to a six-year-old, you don’t understand it yourself. — Albert Einstein Compliance professionals are in a heady state these days. Their stock is rising; they are gaining influence and authority, and even some additional resources. When given the time, compliance professionals can come up with new and innovative strategies for compliance programs. But I see a danger lurking in the...
Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality. Her profile is here and she can be reached at [email protected]. Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....
Lauren Connell from The Volkov Law Group joins us again for a posting about the implications of the FIFA Scandal. Her profile is here and she can be reached at [email protected]. Everyone is talking about the latest corruption scandal, this one with world-wide impact. The scandal engulfed FIFA as seven organization officials were recently arrested in Switzerland. Charges include a range of money laundering, racketeering,...
