Chief compliance officers have a difficult job (to say the least).  If everything goes well, they are hailed as heroes.  If a major problem occurs, everyone looks to the CCO to find out why the problem occurred.  In the latter situation, the implicit message to CCOs is “why didn’t you prevent this problem, I thought you were supposed to prevent this.”  This reflects a fundamental...

Choose to be optimistic. It feels better.” – Dalai Lama Forgive me for my optimism.  It is the only way to live a meaningful life.  Or as some would say – being a pessimist is too much of a burden.  We begin a New Year — and I am optimistic. To turn the corner here on relevance, ethics and compliance professionals, are by definition, optimists. Give...

Chief compliance officers are always hungry for benchmarking data, for comparisons and insights around how their respective compliance programs stack up against other companies, especially in the same industry.  Compliance professionals, as a general rule, are collaborative and willing to share information with each other.  CCOs are an optimistic lot and enjoy sharing best practices, ideas and insights in order to further the ethics and...

Perhaps I am little bit behind.  That would be nothing new – but we are getting to the point where we no longer need to spell out ESG.  Everyone knows what it means – directors, officers, employees, investors, shareholders and other stakeholders can spell it out.  ESG is firmly implanted in the corporate governance landscape.  Prosecutors and regulatory agencies are quickly adding ESG to their...

Boeing’s long and tragic scandal surrounding its 737 MAX safety concerns and FAA disclosure violations has come to an end.  DOJ announced a settlement early this year, on January 7, 2021, which included a three-year deferred prosecution agreement (DPA) in exchange for total payments of $2.5 billion, consisting of: a $243.6 million criminal penalty, $1.77 billion in compensation to its airline customers, and $500 million to establish...