The Sound & Fury of Trump Regulation


Setting corporate strategy and regulatory compliance has never easy during the Trump Administration, and an article from the New York Times earlier this week demonstrates why that’s so. The article is worth a compliance officer’s time, since it’s quite possible we’re about to enter a period of even greater regulatory and political mess. The piece…

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Dealers, Drugs, and FCPA Insight


I always welcome questions from compliance and audit professionals, and the following came to me last week: “What type of third party falls under ‘dealer’ for FCPA purposes?” The compliance officer who posed this question works at a company under settlement with the Justice Department for overseas bribery. He’s building up the company’s third-party oversight…

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Podcast: Lease Accounting Compliance Update


Confession: I love the new accounting standard for companies to report their costs for leases. Not so much because I applaud what the standard tries to accomplish (although I support that too) but rather, because implementation of the standard demonstrates so many compliance and internal control headaches today. Hear me out. The new standard —…

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Podcast: CCOs Serving on Boards


Regular readers of Radical Compliance know that I believe ethics and compliance officers serving on corporate boards is a superb idea. More and more of the governance challenges boards face, as they try to position their organizations for success, somehow touch upon ethics and compliance issues. Well, who understands those issues better than professional ethics…

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Facebook, Power, and Antitrust Issues

Compliance officers have a lot to consider about this week’s news that Facebook will pay $5.1 billion in penalties and implement a raft of procedures to improve its privacy compliance. Above all, however, consider this: the market didn’t care.  It didn’t. While we were all busy analyzing what Facebook’s settlements with the Federal Trade Commission…

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More on Embedding, Automating Controls


Last week I had a post about an SEC enforcement action against rent-to-own retailer Conn’s, where the SEC dinged Conn’s for using manually updated forecasting tools to estimate customer credit risk. Executives had low-balled their estimates for years, until that short-sighted maneuver finally forced the company to cut earnings and the share price tanked. Today…

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How Good Training Finds Its Wings


I spent most of last week on vacation in California, which required a cross-country flight to get there. Since compliance professionals fly all the time, you know what that means: flight safety videos.  And, naturally, thoughts on compliance training.  After all, one of the biggest challenges for compliance training is how to keep the material…

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Random Compliance on My Mind…


Random thoughts about compliance, audit, and risk management to keep you entertained while I’m away on vacation this week…  The OFAC framework for sanctions compliance is an outstanding document. I understand that implementing its recommendations may be a pain in the neck, but it packs a tremendous amount of information into 12 pages. Line for…

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What Drives ‘Open Secrets’

open secrets

So there I was this week, attending the annual conference of the Association of Certified Fraud Examiners in Texas. ACFE had asked me to moderate a keynote interview with Tyler Shultz, the immensely brave employee who endured personal and professional pressure to blow the whistle on Theranos.  You might already know the tale. Shultz, 28,…

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Tackling AI and Ethics Issues Intelligently


You can learn a lot from Google — including, apparently, how corporations might approach the delicate matter of ethics and artificial intelligence. Because Google tried exactly that not long ago, failed in a painfully public way, and raised numerous AI lessons for ethics and compliance professionals to consider before your company tries this at home.…

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