Tagged: resources

The Importance of Independence to a CCO’s Role

It is easy to be dogmatic in blog postings — to express an unvarnished opinion that sounds valid.  While it may not be supported by hard data or valid evidence, compliance officers are used to trusting their “gut feelings,” when it comes to compliance.  Compliance professionals with experience agree largely on big ticket issues, and this view often reflects lots of real-world experience.  Sometimes the...

What Happens When the CCO is Buried in the Organization?

Let me paint a picture for you.  It is not pretty.  Unfortunately, this picture occurs all too often in the corporate governance landscape.  The first picture captures the presence of chief compliance officer in a stand-alone office in a mid-size public company.  The company is not subject to any robust regulatory regime.  The CCO has a staff of one or two people, coordinates some compliance...

Compliance Titles and Responsibilities

Let me start with yet another profound grasp of the obvious — leadership requires many important interpersonal and intellectual capabilities.  I do not intend to list the important ones right now but leadership requires an understanding of influence and the use of symbolic actions that may resonate through an organization and its constituents. Effective leaders understand know that symbolic acts drive organizational behaviors.  Symbolic actions...

The DOJ’s Self-Disclosure Program Is Not Even Half the Story

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on DOJ’s recent FCPA guidance announcement.  Lauren can be reached at [email protected]  Her bio is here.   Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One...