We are living in a rapidly changing economic landscape. Companies are under the gun to navigate “traditional issues,” such as challenging economic conditions ranging from inflation, and a predicted recession, to supply chain disruptions. It has been a long and difficult path in responding to two significant crises – first the pandemic in 2020 and then Russia’s invasion of Ukraine and the resulting global sanctions...
It is hard to follow all the news, events and political trends across the globe. To the regular observer, the ability to identify, measure and respond to evolving risks has become more chaotic and near impossible. Risks are multiplying exponentially — it can be overwhelming. In the end, however, ethics and compliance professionals (“E&C officers,” Chief Compliance Officers (“CCOs”),” and “compliance professionals”) have several strengths...
If I ever told you years ago that the 2021 headlines would be dominated by the “supply chain” crisis, you would have immediately questioned my judgment (and perhaps sanity). The current crisis reflects the roller coaster economic impact of the pandemic. If there ever was a global disruption of severe magnitude, we have been through it. We have all had experience in managing disruptions and...
We often hear the adage – “compliance has to understand a company’s business;” “compliance has to work well with the business side.” While I generally agree in principle with these phrases, there is a more important point here. A compliance professional has to understand a business, the specific business processes, and its operations. In other words, a compliance officer has to understand step-by-step a business...
The COVID-19 pandemic uncovered the fragility of business operations – within the space of weeks, companies were forced to adjust to distribution channel and supply chain disruptions, workplace closings, and a virtual standstill in global trade. The global economy came to a screeching halt. While the economy is slowly recovering and poised for increased activity, consumers and investors have discovered the importance of organizational sustainability. ...
Chief compliance officers (CCOs) are talented professionals. As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation. CCOs focus on legal and compliance risks as reflected in an organization’s Code of Conduct, ethical culture and legal requirements. In recognition of their unique role in every organization, CCOs have line of sight across the organization, independence and authority to...
Tuesday, March 16, 2021 1 PM EST/10 AM PST Sign Up Here When it comes to risk, you don’t know what you don’t know. And, in some cases, you don’t know what you do know. The latter can describe the current state of third-party risk management. This session will explain how to create a forward thinking risk management program that identifies and incorporates all the risk information...
Banking regulators have been flexing their muscles. With the coming Biden Administration, this may portend the beginning of a new, enforcement wave. Some have suggested that banks are resolving these cases before a more aggressive approach is taken by the new Biden Administration. Citigroup recently was tagged for $400 million by the Treasury Department’s Office of the Comptroller of the Currency (OCC). The OCC also...
Every company has done it. Chief Compliance Officers have had to hold their respective noses and push forward with due diligence to retain a risky third party. Rather than reject the third party, a CCO convinces him or herself that the company can mitigate the risks by contract representations and warranties, annual certifications, and a plan to monitor and audit the third party in the...
I find myself quibbling with compliance terms – hyper focus on small issues is not a positive trait. I often urge clients and colleagues to focus on issue of more significance and leave the smaller ones for another day. Hence, my recent criticism over “due diligence” policies and procedures for third party intermediaries. A more appropriate title is “risk management.” A due diligence inquiry of...
