Thomson Reuters’ Henry Engler compiles guidance from the Chief Compliance Officers at Volkswagen, Novartis and Tenneco – principles that transcend their respective industries and are universally applicable. Prompt acknowledgement of internal wrongdoing and transparency over the lessons learned from conduct failures were just some of the keys to a strong corporate culture cited in a recent wide-ranging discussion on what...
Recent growth in the science of behavior has introduced new tools to the compliance officer’s toolbox. Vasco Brazão and Tania Ramos of CLOO argue that, despite our best intentions to do what is right, we often fail to act accordingly. Ethical nudges can help organizations steer their employees into ethical behavior, and compliance officers should take note. Ultimately, the job...
Entertainment and comedy can be a hugely effective way to get compliance and risk training to “stick.” Ronnie Feldman builds a business case for more creative approaches to training and communication. Let’s talk about comedy and corporate risk. Using humor and other entertaining devices to train and communicate ethics, compliance and other corporate risk topics may seem counterintuitive. After all,...
Employers must make clear to their employees what compliance topics and policies are essential to the organization. As Skillsoft’s John Arendes explains, it’s to the employer’s benefit to help employees deal with information overload. The workplace continues to evolve over time; from the impact of startup cultures to new technology, it is not the same place as my first investment...
Coalfire’s Adam Salerno discusses the process, effort and rewards of designing and implementing an automated compliance environment, as well as what organizations can do to automate security controls to meet specific compliance framework requirements. Enterprises serving multiple highly regulated industries – and those overperformers wishing to demonstrate “above and beyond” security statures – can juggle 15 or more compliance frameworks....
Compliance is near the top of nearly every health care provider’s list of priorities. But what does a robust compliance program really look like? Ty Howard, Partner at Bradley Arant Boult Cummings, offers insight from the DOJ’s recently updated guidance. On April 30, 2019, the Department of Justice (DOJ) Criminal Division released a new guidance document intended to assist prosecutors...
The Trump administration’s policies toward Cuba have recently shifted, creating some urgency for U.S. firms that do business with the embattled country and its regional partners. Michael Carter and Drew Marrocco detail what American companies need to do to maintain compliance. Introduction The United States recently announced that it would enforce a number of sanctions directed at individuals and companies...
In the #MeToo era, with allegations of workplace misconduct on the rise, organizations need a quick and accurate way to evaluate claims. Hanzo’s Sean Freidlin asserts that the internet is a hotbed of potential evidence — if you can sort through it and make sense of it all. They say, “where there’s smoke, there’s fire,” but that’s not always true....
State agencies are pushing the envelope with respect to their regulatory enforcement authority. Venable’s Randy Seybold and Andrew Kay explore how the resulting increase in improper “regulation through enforcement” actions presents a serious challenge for companies. In recent years, changes in the economic and political landscapes have created an environment ripe for increased scrutiny and oversight by state regulators of...
The government of China recently announced its intentions to publish a list of foreign entities that harm the interests of Chinese companies. Attorneys from Clifford Chance discuss the particulars and how the “unreliable entity list” will have immediate impact to the businesses listed therein. with co-authors Hena Schommer and Nick Turner China's Ministry of Commerce (MOFCOM) introduced a new layer...
Duff & Phelps’ Global Regulatory Outlook report found that while financial institutions globally are devoting considerable energy and resources to AML efforts, there is still work to be done at the firm level. John Arvanitis discusses. The increasing complexity and regulatory scrutiny of combating money laundering has put the spotlight not only on a financial institution’s AML program, but also...
Over the last five years, the Justice Department has struggled to establish a firm set of rules and expectations surrounding corporate criminal liability. Competing factors have made the process murky, as Volkov notes here. But the stakes are high. Today's savvy compliance professional should explore this difficult but critical issue by carefully examining the path DOJ has taken thus far....
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