Caldwell Lays it Out – DOJ Metrics for a Compliance Program

The DOJ has recently hired compliance counsel who will help the department determine which companies and individuals to prosecute, distinguishing between entities that are serious about compliance from those whose commitment exists only on paper. Assistant AG Caldwell has since remarked on the expectations of companies’ compliance programs. Take note!


What’s Your Compliance Plan?

Chief Compliance Officers need to be both leaders and managers. Long-term planning must be in the CCO’s wheelhouse, but a CCO is at his most effective when he’s an inspirational leader who’s also able to effectively manage the compliance process. Where do you stand? Do your staff look to your leadership and echo back what they ...


How’s Visibility in the C-Suite?

For a CCO or compliance practitioner to do his job well, he’s got to have a clear picture of the risks at hand. This is especially critical when it comes to third party transactions. Armed with all the pertinent information at once, he can much more easily spot corruption risks, unusual payments, control violations and other red ...


Why Compliance Should Widen Its Circle

A wider network is valuable to compliance practitioners for a number of reasons. Broadening one's exposure to alternate viewpoints can be critical in improving the collective intelligence of your leaders. Preventing compliance from being viewed as "the land of no" necessarily means remaining open to different ideas. Compliance leaders, check your ego at the door.

VW passat

The Psychology of Cheating and FCPA Compliance

There are basically three varieties of corporate scandal. Volkswagen may have the dubious distinction of having pioneered a fourth, however. VW's emissions-testing scandal is result of its top leadership and senior engineers intentionally deceiving the public. This was no slow slide into fraud; there was at one point a specific decision made to cheat.


Creating Trust to Affect Compliance Change

One of the greatest challenges corporate compliance practitioners face is securing buy-in from staff on compliance objectives, as well as their participation in meeting these goals. To do that, the compliance function can't be viewed as "The Land of No," but as a valued partner in the success and profitability of the business. So where do we ...


Highway 61 and IRS Involvement in FCPA Enforcement

If you need a reason to bolster your monitoring efforts, you may find the recent FCPA enforcement action against Vicente Eduardo Garcia to be quite instructive. One noteworthy feature of this investigation was the involvement of the IRS’s Criminal Investigation unit, the lesser-discussed of the DOJ’s two investigative bodies, called in to comb through mountains of data and ...


Farewell to Chocolate Thunder, Baylor Football and Due Diligence

Just as the football season kicks off, Baylor University is embroiled in scandal. One of the football team's prized recruits was recently convicted of sexual assault. Part of the trouble here is that the university doesn't seem to have done its homework on the athlete. When the story of his conviction broke, the finger pointing began. ...


Amazon’s Culture, the Greatest Brawl in Baseball and Compliance

Amazon has long been known for its dynamic culture, but it's becoming increasingly evident that the company's culture has a seedy underbelly. Workers are treated miserably, and programs presumably designed to improve employees' experience are being used to punish them and pit one team member against another. What does this mean for the compliance practitioner? Read on.


Georgia On My Mind – How Does Compliance Enhance Shareholder Value?

What does the compliance function do to increase shareholder value? It's a question you've no doubt heard before, in some form or another. Tom Fox argues that no company with strong internal controls is run more poorly because of them. No -- in fact, stakeholders are necessarily better off when the company is kept on the ...