The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand, has been steady this year — the Albemarle and Clear Channel enforcement actions are numbers eight and nine for the year. The Albemarle enforcement action...
Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance program is a subset of a company’s internal controls. So, all this is well and good. But it appears that a number of companies have been getting into trouble because they...
Congratulations on your new position as the chief compliance officer. You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package. You are feeling “pretty, pretty good” (ala Larry David) about your new job and looking forward to starting your new position. So, now, what do you do? My first question for you is...
A chief compliance officer can only succeed with the support of other important compliance partners. Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the kindness of strangers.” This observation, while dramatic in license, applies to the place of the compliance officer in the corporate governance world. A key partner for compliance...
DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s concern that companies tailor their training programs to their specific risk profile. In the FCPA Guidance issued in 2012, DOJ explained that training programs should be tailored to specific audiences. DOJ has refined this requirement to focus...
I was honored to participate in a brief podcast conducted by the MIS Training Institute, the International Leader in Audit and Security Training. The link to the podcast is here.
