Effective change management and effective compliance don't have to be mutually exclusive terms, though the concepts are often viewed as at odds with one another. One way to bring change management into alignment with compliance (and vice versa) is with the use of video-based training, a solution that is not only more efficient, but also potentially simpler and more impactful.
When assessing compliance challenges ahead of an expansion into a new market, the CCO or compliance practitioner has quite the job on his or her hands. Tom Fox offers up four basic questions to consider when walking through analysis, third-party due diligence and developing a plan to ensure ongoing compliance both with the FCPA and any in-country regulatory requirements.
That a certain market is high-risk is no reason not to do business there. If entering into the Russian or Chinese market, for example, can be financially advantageous, your CCO ought to be able to develop a program and budget to prevent and detect violations there. The catch is that the CCO must be involved in the discussions regarding whether...
The health care industry has been no stranger to the consequences - reputational and financial - of non-compliance over the past few years. The entities that have managed to maintain good standing with the OIG have also enjoyed a continued positive public reputation. Those that have been found guilty of significant infractions (GSK, Johnson & Johnson, Stryker) are paying dearly.
We have become increasingly interconnected, and so have our devices. Some sources state that in as little as six years, there may be as many as 26 billion devices on the Internet of Things. With this much growth comes a great deal of risk, particularly when the devices going "online" are associated with patient care. Sensitive information in the wrong...
Between 2008 and 2010, Wyndham was subject to three data breaches, exposing more than 600,000 of its consumers and leading to millions in fraud loss. Its shareholders filed action against the Board earlier this year, alleging negligence, and a decision (dismissal) was reached in late October. Though Wyndham's leadership was not ultimately held liable in this case, there's much to...
The U.S. Financial Crimes Enforcement Network is expanding its customer due diligence requirements, a change that would mandate greater efforts on the part of banks and other entities to identify the owners of the companies they service. This requirement, though likely somewhat challenging, would bring the U.S. into alignment with its G8 commitments.
CCI's Founder and CEO, Maurice Gilbert, recently connected with Roy Snell, CEO of he Health Care Compliance Association and the Society of Corporate Compliance and Ethics. Roy had some excellent insights to share on the state of the compliance profession, and when an expert with experience and credentials such as his weighs in, we sit up and take notice.
It appears the Department of Justice may be changing its tune on what makes an "effective" compliance program. Recent statements by authorities at the DOJ's Antitrust Division signal a shift in tone for the agency, toward leniency and away from a strict, hard-line approach. Read more about the apparent change here and what it could portend for your organization.
Ukraine has certainly had its share of difficulty in dealing with corruption. Among its challenges has been the apparent stunted attempt at holding legal entities criminally liable for their representatives' wrongdoing. Though legislation was put in place nearly 18 months ago establishing the criminal liability of legal entities, no enforcement in this vein has yet been handed down.
Theory has its place, but you'll be hard pressed to find a compliance practitioner who wants to entertain theory over practical solutions. What compliance professionals need is actionable recommendations and grounded guidance. These constitute effective support. The bottom line: we're all short on time, so if you're contributing to the compliance function, cut to the chase.
Corporate executives and Boards could take notes on transparency and leadership from FIFA. On what not to do, that is. FIFA has come under fire for its selection of Russia and Qatar to host the 2018 and 2022 World Cup games. Allegations of corruption followed, as did an investigation, but FIFA appears to have botched the release of the findings,...
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