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...

Some things are easy to define by negative inferences. Corporate ethics or business ethics are not the same as legal ethics. Business ethics are not the same as our philosophy ethics – Aristotle and all of the classic philosophers were not operating in a corporate context. Some things require a positive definition. To bring about real change in the area of business ethics, a clear...

Before a Chief Compliance Officer accepts a new position with a company, a potential CCO should conduct his/her own “due diligence” of the prospective employer. A company without a corporate culture of ethics and compliance can pose serious challenges for CCOs seeking to implement an effective ethics and compliance program. In the absence of a real commitment from the board and the CEO, a CCO...

“It is Time” – Rafiki, The Lion King Corporate scandals continue to rack up – I am not just blowing smoke on this fact. Corporate boards are under greater scrutiny but the hardest place to bring reform is the corporate boardroom. Old institutions do not change quickly and there is an inherent resistance to change when it comes to a corporate boardroom. The old dynamic...

As a federal prosecutor with lots of trial experience, I generally know what questions to ask a witness or a defendant.  In the compliance arena, there is much more leeway in how and what questions you ask. Many companies conduct employee surveys. These surveys are usually administered by human resources across the organization every year or two. I do not oppose these surveys but recommend...

Integrity has no need of rules. – Albert Camus Corporate decision-making ignores important principles and sometimes, common sense. With the increase in corporate compliance programs, corporate boards and senior executives need to take a moment to address one important issue – the importance of creating an ethical culture. For some reason, corporate boards and leaders like to focus on the tangible aspects of ethics and...

Groucho Marx was (and is) my hero. No one else had a sharper wit.   One of my favorite scenes was in Duck Soup when Groucho conducts a meeting as the President of Fredonia. Here is the clip. In particular, when Groucho is given a report and looks through it and says, “Why, even a four-year-old child could understand this report.” He then flips the report...

I am excited to support Leona Lewis, a compliance consultant, who has launched a new podcast — Masters of Disaster, in which she interviews professionals in the fields of risk, ethics and compliance. I was happy to be interviewed by Leona several weeks ago.  The podcast is available here.  My interview focuses on the importance of ethics and creating an ethical culture. Leona is a...

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...