• Operationalizing Compliance: Part IV – Internal Audit
    This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined… ... read more
    Source: Blog FeedPublished on 2017-05-25
  • Day 18 of One Month to Better Compliance Through HR-Using Promotions to Operationalize Compliance
    The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antithetical to HR, the company certainly is not hitting on all cylinders and maybe moving towards dysfunction. Another way you… ... read more
    Source: Blog FeedPublished on 2017-05-24
  • Day 18 of One Month to Better Compliance Through HR-Using Promotions to Operationalize Compliance
    The role of Human Resources (HR) in anti-corruption compliance programs, is often underestimated. If your company has a culture where compliance is perceived to be in competition or worse yet antithetical to HR, the company certainly is not hitting on all cylinders and maybe moving towards dysfunction. Another way you… ... read more
    Source: Podcast FeedPublished on 2017-05-24
  • Compliance into the Weeds-Episode 39, Disclosure of Ransomware Attacks
    In this episode Matt Kelly and I take a deep dive into the question of whether a company has a duty to disclose ransomware attacks. We consider it from the regulatory, legal, ethical, law enforcement, business, PR and some other angles. What may seem to be a straight-forward answer to… ... read more
    Source: Blog FeedPublished on 2017-05-24
  • Operationalizing Compliance: Part III – Human Resources
    This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined… ... read more
    Source: Blog FeedPublished on 2017-05-24
  • The FCPA Year in Review-the book is out
    I am excited to announce at Compliance Week 2017 the publication of my latest book 2016-The Year in Corporate FCPA Enforcement: Cardinal and Provident, published by Compliance Week. In it I take a look the most prolific year in FCPA enforcement and what it means for the compliance practitioner. We… ... read more
    Source: Blog FeedPublished on 2017-05-23
  • Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture
    The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical culture is an important step for any company to burn compliance into the DNA of a business. It must be done at… ... read more
    Source: Blog FeedPublished on 2017-05-23
  • Day 17 of One Month to Better Compliance Through HR-Using HR to Create an Ethical Culture
    The Evaluation of Corporate Compliance Programs document makes clear that operationalization of compliance into an organization should be done at multiple levels in a company. Creating an ethical culture is an important step for any company to burn compliance into the DNA of a business. It must be done at… ... read more
    Source: Podcast FeedPublished on 2017-05-23
  • Operationalizing Compliance: Part II – Breaking Through Obstacles
    This week I am engaging in a week-long series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I am joined in this exploration by Russ Berland, a well-known compliance commentator and practitioner who recently joined… ... read more
    Source: Blog FeedPublished on 2017-05-23
  • Day 16 of One Month to Better Compliance Through HR-the Exit Interview
    The exit interview can be a further mechanism to operationalize compliance. This type of interview is used when someone voluntarily departs from a company, as opposed to a lay-off or reduction in force exercise. Typically departing employees are more willing to share about their experiences, concerns and issues which led… ... read more
    Source: Blog FeedPublished on 2017-05-22
  • Day 16 of One Month to Better Compliance Through HR-the Exit Interview
    The exit interview can be a further mechanism to operationalize compliance. This type of interview is used when someone voluntarily departs from a company, as opposed to a lay-off or reduction in force exercise. Typically departing employees are more willing to share about their experiences, concerns and issues which led… ... read more
    Source: Podcast FeedPublished on 2017-05-22
  • Operationalizing Compliance: Part I – It All Starts with Pizza
    With the release of their Evaluation of Corporate Compliance Programs (Evaluation) in February, the Department of Justice (DOJ) emphasized yet again the importance of actually doing compliance and not simply having a paper program in place. The term which has come to the forefront is operationalization of compliance. The Evaluation… ... read more
    Source: Blog FeedPublished on 2017-05-22
  • This Week in FCPA-Episode 53, the I left my heart in San Francisco edition
    Show Notes for Episode 53, for the week ending May 19, the I Left My Heart in SF Edition This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: Brazilian President Temer comes under corruption fire? See article in the… ... read more
    Source: Blog FeedPublished on 2017-05-19
  • Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
    Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for concerns that impact the compliance practitioner. Yet there are several ways that operationalization will help to protect… ... read more
    Source: Blog FeedPublished on 2017-05-19
  • Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
    Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for concerns that impact the compliance practitioner. Yet there are several ways that operationalization will help to protect… ... read more
    Source: Podcast FeedPublished on 2017-05-19

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