The Third Man and the Authority of Chief Compliance Officers

Whatever your company's stance on to whom the Corporate Compliance Officer should report, what's not in question is that the CCO must be able to act from a place of authority. Strip the CCO of his power and influence, and your compliance program is bound to fail. Tom Fox walks us through five key indicators that a ...


Commodore Perry and Integrating Compliance into the Fabric of Your Company

When the compliance function isn't fully integrated into a company's DNA, there's bound to be a clash of priorities. In these cases, it's often financial objectives that take precedence. As we all know by now -- and pardon the throwback to Compliance 101 -- that simply won't do. Paper compliance programs don't cut the mustard. ...

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Channeling John Steed in Your Tone in the Middle

A strong tone at the top is essential to maintaining a culture of compliance. Equally as important, however, is tone in the middle. If your middle managers don't understand or aren't on board with a commitment to operate with integrity and in compliance, the message they project to their teams won't likely be reflective of the organization's ...


Bristol Palin, Abstinence and the Compliance Defense

Newsflash: compliance programs are only effective when they're being put into practice. Having a paper compliance program is no kind of defense... just like claiming to be abstinent while acting otherwise didn't keep Bristol Palin from her latest pregnancy. And like Ms. Palin, some will find there are consequences of SAYING you're adhering to the compliance program ...

Daniel M. Silva /

Never Tick Off a Redbird

Baseball's St. Louis Cardinals are being investigated by the DOJ and the FBI for allegedly hacking into the Houston Astros' database. You read that right. One of the National League's best performing teams was after the secrets of one of the worst teams in the League. In a world where successful entities attempt to steal data ...

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FIFA, the DOJ and the Global Fight Against Corruption

The first step to recovery is admitting you have a problem. Let's grab onto that metaphor. Despite corruption that's been endemic for years, FIFA has not only not yet taken that first step, the organization is still balancing precariously on wobbly legs. With the DOJ having recently charged more than a dozen FIFA officials, however, the ...

John de la Bastide /

The FIFA Indictments and Travel Act Prosecutions under the FCPA

Last week, 14 officials and individuals associated with FIFA were indicted on corruption, racketeering, and conspiracy charges. And while the defendants haven't exactly violated the FCPA, U.S. authorities are bringing charges under the Travel Act, which prohibits the use of the mail or any facility in interstate commerce to engage in illegal activity.

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Levi Strauss and Auditing of Third Parties

This year's Compliance Week conference was rife with excellent speeches from compliance experts. Tom Fox shares with us the highlights of one presentation from Baker Hughes' Marianne Ibrahim and Jennifer Ellison, whose address on planning for audits was truly illuminating. A must-read piece for any practitioners establishing or tweaking their audit protocols.

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A CCO Job Function: Managing Talent

CCOs have a big job, no question. In addition to developing and strengthening the compliance program and remaining attentive to ethical concerns throughout the organization, the CCO has the responsibility of managing his bench of compliance practitioners. Given the egos often prevalent among top talent, this is no small feat...