Compliance

Tom Fox raises an interesting question: when fault is found with leaders at the heart of a scandal or a major violation, they may face termination - but should they be allowed to retire instead, benefits intact? Here he explores three recent examples of corrupt leadership and the companies' subsequent responses. There are some key lessons to be learned here.

The costs can really add up when internal investigations get underway, but cutting corners is generally a bad idea. Particularly during the interview process. If you're serious about uncovering the truth, the important interviews should be handled by experienced attorneys, not by counsel a bit greener around the edges who will be less likely to pick up on hints of...

On the surface, asset forfeiture sounds like a noble practice: disincentivize crime by confiscating the fruits of criminal conduct. Wonderful! I think we can all get on board with that notion. Put the laws into practice, however, and things can get a bit sticky. Asset forfeiture can impact both the perpetrators and the innocent connected to the criminal either personally...

There's more than one way to skin a cat - whether we're talking about putting on an incredible rock show or running an effective compliance program. Keep in mind, though, that however your compliance program is fleshed out, if and when an investigation begins, the DOJ will look not only at its components, but also how it's been implemented.

Compliance is critical, of course, but at the end of the day, it's of little consequence if the company's operating in the red. And while profitability shouldn't be the sole factor in the CCO's decision-making process, it must figure in there somewhere. The trick is to strike a balance between profits and compliance and to know when compliance must take...

The Trans-Pacific Partnership has yet to get off the ground, and the most recent talks in July failed to progress the partnership in any significant way. Japan stands to gain the greatest benefit from the TPP, so they're holding fast on their terms, while the U.S. remains focused on protecting the interests of SMEs stateside. Will the partners reach an...

Solid compliance programs are built on solid risk assessments, so the importance of a thorough risk assessment can't be underestimated. Jeff Kaplan has provided us with a wealth of information over the years in this vein, and today he's covering some of the questions he hears the most from compliance and ethics practitioners. Check in for some expert guidance.

Last year, the Financial Crimes Enforcement Network (FinCEN) updated their Suspicious Activity Report (SAR) form to allow for far more detail to be provided. The SAR is an integral part of an investigation of alleged financial crimes, and with the expanded form, law enforcement is able to get a clearer picture of the incident or incidents in question.

We're inundated with survey requests, and they seem to come from all directions - pop-ups on websites, grocery store receipts, in the wrap-up lingo at the end of a customer service phone call... But is this really the best way for companies to be gathering information on their customer experiences? Linda Henman suggests not. Sometimes the more conventional approach is...

A burn-after-reading approach to handling data security might be sexy, but it's not terribly practical. And except in very extreme circumstances - say, if you're dealing with international spies - it's altogether unnecessary. There are far more sensible solutions on the market already, and encrypting data, rather than attempting to restrict access to its location, is the key.

Sharing content on social media requires a bit of strategy in order to be most effective. To really engage the audience, your firm should create "snackable" versions of its material, avoid pitching or selling and put a good deal of thought into how information is shared, where it's posted, and when it's pushed out. Joanna Belbey offers excellent guidance on...

Conducting due diligence on third parties isn't about diving deep into every possible avenue for wrongdoing. You'd never reach the end, and it is impossible to foretell which agents will engage in corruption. Trying to pinpoint possible red flags must be guided by reasonable inquiries tied to risks. Cover your bases and you'll have covered your bottom as well.