August 31, 2015
Promoting Your Culture: Communications and Measurement

  • Michael Volkov

  • The most beautifully written policies and procedures are worth little more than the paper they're printed on if ethics isn't woven into the fabric of an organization's corporate culture. Ethics must be promoted from the C-Suite, with the CCO and CEO proactively communicating the importance of doing business ethically, as well as identifying and closing ethics gaps to minimize misconduct....

    August 27, 2015

  • Thomas Fox

  • What does the compliance function do to increase shareholder value? It's a question you've no doubt heard before, in some form or...

    August 25, 2015
    When a Regulator Calls: The Use of Information Obtained From Compulsory Examinations - Lessons From the Australian Experience...

  • Wendy Wysong

  • Regulators can and do compel witnesses to provide information in the course of an investigation. And at times, regulatory agencies have used that evidence, obtained compulsatorily, to prosecute the very witnesses that coughed it up. Have these witnesses' right to silence have been violated? If a regulator calls, you'll want to know your rights!...

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    August 28, 2015
    Multi-Party Conspiracies in Central America: The Latest FCPA Case

  • Matteson Ellis

  • The recent FCPA investigation and enforcement action against Vicente Eduardo Garcia, a former executive at SAP International, revealed an individual intent on circumventing internal controls, one who knew the illegality of his actions and went to great lengths to disguise them. Lessons for the compliance practitioner? For starters, violations can occur without actual payments....

    August 26, 2015
    Q&A with Fabiana Lacerca-Allen

  • Maurice Gilbert

  • Recently CCI's CEO, Maurice Gilbert, had the chance to interview Fabiana Lacerca-Allen, President of Ethiprax, a compliance consulting firm based in San Francisco that serves clients in the health care and life sciences industry. Ms. Lacerca-Allen, a thought leader in compliance, reflects today on what's made her successful and how the compliance landscape is changing. ...

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    August 24, 2015
    Classifying Employees as Exempt from Overtime May Become a Lot More Costly

  • Robin Largent

  • The Department of Labor announced a proposed rule in early July to extend overtime protections to millions of white collar workers. This change would protect most staff from working overtime without the benefit of overtime pay -- quite a blow to employers who've taken advantage of the exemption thus far. The DOL is seeking comments on the proposed change through September 4. ...

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    August 21, 2015
    Amarin Pharma Decision Reiterates Importance of Disclosures in Off-Label Promotion

  • Brian A. Dahl

  • In a follow-up to June's pieces on the Amarin complaint, Brian Dahl responds to the FDA's disregard for the decision in United States v. Caronia, in which the Second Court ruled that the FDA must limit its restrictions on truthful, non-misleading off-label promotion. The implications of truthful speech are better informed treatment options. Or isn't that what the FDA wants?...

    August 20, 2015
    Reflections on a Failure of Leadership

  • Jim Nortz

  • Strong leaders don't just know the right thing to do, they want to do it and then make it happen. Jim Nortz shares an experience in which he saw need for drastic, immediate change, pulled the necessary stakeholders together to devise a strategy, and then watched as the would-be plan fizzled and died. There were multiple failures that day, and Jim admits his was one of them....

    August 19, 2015
    Lessons Learned from the Nepal Crisis

  • Jim Hutton

  • When employees are traveling on business, some risks are inevitable. However, every organization should have a fully realized plan in case the worst occurs. The best way for employers to avoid danger is by being proactive in case an emergency strikes, being aware of risk, training employees, understanding the capability on the ground and crowdsourcing intelligence....

    August 17, 2015
    U.S. Supreme Court Sides With EEOC in Abercrombie Headscarf Case

  • Robin Largent

  • In June the U.S. Supreme Court handed down a ruling in the EEOC v. Abercrombie & Fitch stores case. The EEOC argued on behalf of an applicant who was denied a position on the grounds that her headscarf would violate the company's no headgear policy. Employers, take note: when company policy and religious accommodation needs meet, the latter trumps the former. ...

    August 14, 2015
    New Focus on Student Data Privacy – How to Navigate it All

  • Grant Waterfall

  • The classroom experience has been revolutionized by advances in school technology; armed with data from student devices, teachers can personalize instruction and provide real-time feedback. And while this technological boom in digital solutions for the classroom is critical to student learning, a major concern remains: how do we ensure the privacy and protection of student data?...


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    August 21, 2015
    Ethics and Compliance Programs in a Global and Brazilian Context: The 6 Principles of Compliance

  • Renata Andrade

  • If you want an ethics and compliance program that's more substantive than the paper it's printed on (and you do), take note: effective E&C programs don't materialize out of thin air; they require some intentionality. Compliance expert Renata Andrade offers up six characteristics of a solid ethics and compliance program. Does yours make the grade?...

    August 20, 2015

  • Diane Wittenberg

  • Assembling an audit committee is child's play. Building one that will be maximally effective, however, takes more finesse. And the strategy extends well beyond se...

    August 18, 2015
    The 5 Most Common AML Compliance Program Deficiencies

  • Michael Volkov

  • Anti-money laundering programs can fail for any number of reasons. In Michael Volkov's experience, most failures in AML compliance can be traced back to at least one of five core shortfalls. The planets don't have to be perfectly aligned for an AML program to work well, but it does require a concerted effort, from the top of the organization to the bottom. How does your AML program look?...


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    August 13, 2015
    ACA Preparedness: Get Ready – The Train Is Coming

  • Tom Perrotti

  • Starting this year, employers with 50 or more full-time employees are required to provide affordable health insurance coverage under the ACA, and to track, manage and report the company’s health insurance data. Begin establishing a reliable and smart compliance tracking and reporting process now to stay on schedule to meet the IRS’s requirements and avoid potential penalties....

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    Bullet Proof 510(k) – Latest FDA Changes to the Process



    A GRC Approach to Manage Cybersecurity, Risk & Compliance Challenges in the Retail Industry



    Business Continuity Management App Overview



    Navigate through Product Compliance Requirements: REACH/RoHS and Conflict Minerals



    How to Prepare an Effective Audit Manual for an Internal Audit Department

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    August 12, 2015

  • Richard Bistrong

  • A short film on Richard Bistrong's journey through the dark side of international business, “getting caught” and what that might mean for today’s compliance challenges....

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    August 12, 2015

  • Matteson Ellis

  • The number of FCPA declinations is on the rise, while the number of enforcement actions is at its lowest level in more than a decade. Now, this doesn't mean companies and individuals suspected of corruption are getting away with anything; instead, the drop in enforcement actions could have everything to do with the fact that the subjects of investigations are playing ball....

    August 11, 2015

  • Amanda Knapp

  • Today Roetzel & Andress attorney Amanda Knapp brings us two vastly different examples of corruption investigations: one a cautionary tale, exposing the consequences of hiding corruption and impeding the investigation once it's found out and the other an encouraging tale, illuminating the benefits of forthrightness and cooperation with the DOJ when corruption is discovered....

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    August 10, 2015
    Social Media Week Part II – Sharing in the Compliance Function

  • Thomas Fox

  • According to social strategist and author Bryan Kramer, there are five types of people who share content on social media. Each type can be of value to an organization as it integrates social media into its compliance program. Considering the merits of each type of "sharer" can also be helpful in determining which employees can best help elevate the compliance function on social media....

    August 7, 2015
    Adversity – Lessons of a Tulip

  • James Bone

  • The tulip was the source of what's widely believed to have been the first speculative bubble, and like all bubbles, it eventually burst. That crisis was not unlike the collapse of the dot-com bubble -- rational behavior was replaced by "irrational exuberance." Effective risk management means being wary of an overvalued market and accounting for human emotion in the pursuit of financial gain....

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    August 6, 2015
    Bending the Cost Curve to Avoid the Cadillac Tax

  • Vic Saliterman

  • For decades, health care costs have outpaced the rate of inflation. Faced with a non-deductible Excise Tax on high-cost health care plans, many employers are re-evaluating their benefits strategies to both hold costs down and attract and retain top talent. Enter private exchanges, the benefits of which include more predictable costs and health care solutions aligned with consumers' needs....

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    August 5, 2015
    Berger FCPA Settlement: Back to the Future

  • Michael Volkov

  • Louis Berger International has agreed to pay $17 million and retain a compliance monitor for three years to settle bribery charges. At the same time, the Department of Justice handed down judgment on two Berger executives. The case, which was settled a few weeks ago, raises questions about the DOJ's handling of similar cases -- specifically regarding the consistency of its strategies....