Jeff Kaplan and Rebecca Walker inaugurate what will be a regular column on compliance & ethics program assessments. Most of our posts will be focused on the “how” of assessing C&E programs, but here, we begin by exploring the “why.” Legal Mandates and Guidance Some of the most powerful drivers for assessments are legal. The first and most influential of...
The modern compliance officer must be constantly evolving to be successful in an ever-changing landscape. Some key attributes he or she might consider adopting are that of a psychologist. ICA’s Jon Prentice explains. Ask any compliance officer the most common question put to them, and most will likely reply: “Can I do this?” or “Am I allowed to do this?”...
Legislative initiatives and a generational shift are changing the dynamics of the American workplace. Cowden Associates’ Elliot Dinkin urges employers to be aware of these developments and the inherent risks. Companies of all types and sizes are using contingent workers at a greater scale than ever before. Beyond the traditional outside contractor, who might perform a discrete set of specific...
As we move ahead in the ethics and compliance world in 2020, Jay Rosen looks back at some of the DOJ policy announcements – specifically at the FCPA Corporate Enforcement Policy, announced in November 2017 – and considers what proactive strategies companies can use based upon the roadmap given in the Benczkowski Memo and policy announcements. Over the next five...
Tens of thousands of respondents have weighed in via multiple surveys, and Gartner analysts have identified 15 legal and compliance hot spots spanning five main trends. Stephanie Quaranta reports on the issues creating or exacerbating the legal, compliance and privacy risks legal leaders must manage. 1. Heightened Regulatory, Trade and Recession Uncertainties Complicate Risk Analysis Regulatory uncertainty, geopolitical volatility and...
Jay Rosen concludes the series with this retrospective from Vin DiCianni on where AMI has been, where it may be going next and what he’s most proud of regarding AMI’s 15th anniversary. There have been a couple of themes articulated by DiCianni over this series. One has been the independence and integrity of AMI throughout its history. In 2004 and...
Whistleblowing is on the rise and may gain further traction from recent stories in the news, increasing the burden on the investigators. H5’s Jeffrey Grobart discusses tools and methods to accelerate the vetting process. From Edward Snowden to the as-yet-anonymous White House whistleblower(s), actions taken by individuals to expose suspected wrongdoing are making headlines, casting the whistleblower process into the...
When Fresenius’ Mary Shirley and her team endeavored to create a compliance department mission statement, they discovered substantial value in executing what seemed at first like a simple task. In 2017, shortly after I joined the Fresenius Medical Care North America Compliance Department, my boss, Lisa Estrada, tasked me with running our internal marketing team (watch for the upcoming Great...
Jay Rosen discusses the combination of compliance and ethics programs with independent monitoring, as well as two DOJ memos that have been key in the selection and application of independent monitors. The marriage of independent monitors and compliance and ethics (C&E) programs has been facilitated through the evolution away from strict regulatory compliance to a more ethics-based compliance. This has...
As it turns out, compiling a final list of the top articles on CCI for 2019 was a lot like planning my menu for next week’s holiday dinner. In both cases, I’m serving a few classic, reliable favorites alongside more recently road-tested fare, plus some new and innovative offerings that are sure to be crowd-pleasers. In other words, both the year-end list...
As we enter a new decade, data will be increasingly valuable for organizations globally. Ground Labs’ Peter Duthie discusses how compliance regulations and security concerns will become more pressing. In 2019, we saw organizations demonstrate that a smart data management strategy can make a huge difference to their bottom line. As an organization collects more and more information, their data...
Jay Rosen shares how the use of independent monitors has greatly expanded over the past 15 years. The increase has been seen in the private and public sectors, domestically and internationally. The U.S. Department of Justice began using monitors in the mid-2000s in a money-laundering prosecution and public construction projects. Independent monitors were also starting to be used by a...
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