Tagged: effective compliance program

Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends

Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices and Industry Trends June 25, 2019, 12 Noon EST SIGN UP HERE The compliance industry is evolving. Recent DOJ and OFAC Guidance are just one influence. At the same technology and innovative strategies using data analytics are quickly eclipsing government guidance, especially in the area of compliance program monitoring, testing and auditing. Companies...

The Emperor Has No [Compliance Program]

At the outset, I have to apologize for the title but during my morning bike ride I usually come up with blog posting titles. But moving past the trite title, I have a point to make. It starts with a hypothetical – a CEO is supposed to introduce a company’s new code of conduct at a company event. Everyone attends – in person or virtually...

Getting to Know You, Getting to Know All About You — Business Buy-In to Compliance Functions (Part III of IV)

We all know that a compliance program without business buy-in is, by definition, an ineffective compliance program. The level of business support ranges from “mouthing” support to full-fledged embrace and ownership of compliance program controls. By “mouthing” support, I am referring to business staff who say they understand compliance, use the right words reflecting an understanding of compliance issues, but they fail to attend to,...

Operationalizing Compliance – Natural Partners and Breaking Down Walls (Part I of IV)

An effective compliance program is built on internal coordination and relationships. Applying the Justice Department’s terminology, an effective compliance program is one that is operationalized. At first glance, you may think this is something new. It is not. The Justice Department’s adoption of the term “operationalized” is meant to distinguish between a compliance program that exists on paper versus a compliance program that is implemented...

The FCPA Pilot Program Disciplinary Standards (Part II of II)

Returning to the FCPA Pilot Project requirements for timely and appropriate remediation, the Justice Department added three new elements, one of which reinforces the CCO “independence” requirement. The two other elements for an effective ethics and compliance program focus on the qualifications and compensation of compliance officers. First, with respect to the structure of the company’s compliance program, the Justice Department listed the reporting structure...

Shortchanging the Compliance Function

A company that does not back up its words with deeds is doomed to suffer compliance and cultural breakdowns. When a company commits to building a culture of trust and integrity, the company has to keep its word. This is not a hard principle to follow. Yet, we hear all too often about company’s leaders who commit to compliance in words and promises of commitment...

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on ISO 37001. Lauren can be reached at lconnell@volkovlaw.com. Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act of 2010 forced a shift and now...

Convergence of Audit and Compliance Functions

Humans have a tendency to make things more complicated than they really are. To capture the flavor of my sentiment, all you need to do is watch the beginning scenes of “History of the World, Part I” by Mel Brooks (Here) to see how simple life was in the early history of man. Returning to the serious subject of compliance, there are some who argue...

The Only Thing You Have to Fear . . . Is No Documentation

Compliance is a profession that requires multi-tasking – another profound grasp of the obvious. But in the multi-tasking world, some principles and strategies are more important than others. My colleague and compliance guru Tom Fox has coined the mantra: “document, document and then make sure you document.” My contribution to this same mantra is along the same lines: “If you do not document, then in...