More Cognizant FCPA Lessons

By Matt Kelly | February 18, 2019 | 0 Comments

Now that we’ve had a long weekend to digest the FCPA enforcement action imposed against Cognizant Technologies last week, compliance officers have a lot more consider here. In many ways what happened with Cognizant is an excellent case-study for corporate ethics and compliance done right, with a few points to ponder about potential risks to…

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$25M to End Cognizant FCPA Case

By Matt Kelly | February 15, 2019 | 0 Comments

IT outsourcing firm Cognizant Technologies agreed Friday to pay $25 million in disgorgement and penalties to settle FCPA charges related to bribery in India, while the company’s former president and top legal officer were indicted for their roles in orchestrating the scheme. The settlement included $19 million in disgorgement of ill-gotten profits, plus $6 million…

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compliance jobs

Compliance Jobs Report: Feb. 15

By Matt Kelly | February 15, 2019 | 0 Comments

The Compliance Jobs Report this week bounces from Georgia Tech (new head of ethics and compliance) to Wells Fargo (new head auditor) to Annaly Capital (new chief compliance officer) and many more. Another merger in GRC vendor world this week, plus four job openings, and our Meme of the Week is a big Valentine to…

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iBusted: SEC Charges ex-Apple Exec

By Matt Kelly | February 13, 2019 | 0 Comments

Well this is juicy: Apple’s former corporate secretary, who helped to craft the company’s policies against insider trading, has been charged by the Securities and Exchange Commission with insider trading. Gene Daniel Levoff, a senior lawyer at Apple for 10 years and the company’s corporate secretary from 2013 until Apple fired him last September, allegedly…

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Supply Chain Risk: We’re Looking at It Wrong

By Matt Kelly | February 11, 2019 | 0 Comments

I was reading the New York Times this weekend when an article jumped out at me: yet another example of misconduct in a large company’s supply chain suddenly bursting into public view, bringing grief to a company that clearly hadn’t known trouble was afoot. Ethics and compliance officers should take note. When we dissect exactly…

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Compliance jobs

Compliance Jobs Report: Feb. 8

By Matt Kelly | February 8, 2019 | 0 Comments

In this week’s Compliance Jobs Report: the new head of compliance at Walmart formally takes the reins; a wave of mid-level hires at Unilever, Boehringer Ingelheim, JP Morgan, USAA, and elsewhere. A notable merger happened in the GRC vendor world, we have the usual rundown of interesting job openings, and we note the passing of…

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Update on Semiannual Reporting: Zilch

By Matt Kelly | February 6, 2019 | 0 Comments

Corporate disclosure mavens, we have an issue that needs attention: Nobody is talking about the SEC’s recent call for comments about moving to a semiannual corporate reporting regime. As you might recall, the SEC published its call for comment in December — 31 pages of questions, asking investors, corporations, and all other interested parties whether…

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Retaliation Against CCOs: Three Tales

By Matt Kelly | February 4, 2019 | 0 Comments

Compliance officers deal with claims of whistleblower retaliation all the time. Today we’re going to recap three examples much closer to home — compliance officers pressing claims of retaliation themselves. We hear those stories from time to time: a compliance officer reports some concern to management (otherwise known as doing your job), and management responds…

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Northam and Ethical Accountability

By Matt Kelly | February 3, 2019 | 0 Comments

Another week, another challenging example of executive misconduct that ethics and compliance officers should consider. Our star this time around: Virginia governor Ralph Northam. Last week photos surfaced from Northam’s medical school yearbook, published in 1984. On one side of the page is Northam. On the other side is a photo of two unidentified men,…

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compliance jobs

Compliance Jobs Report: Feb. 1

By Matt Kelly | February 1, 2019 | 0 Comments

The Compliance Jobs Report this week opens with the top compliance officer at GE jumping to Google; Citi poaching a top Morgan Stanley exec to be Citi’s CCO in Europe; more news from Orthofix, Getinge, and even Elf on a Shelf! A GRC vendor is changing its name after raising $30 million in funding, and…

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About Us

Technically, Radical Compliance is the personal blog of Matt Kelly, long-time writer and observer of the corporate compliance and GRC scene. I was a writer, editor, and publisher at Compliance Week, 2003 through 2015; some of you may know me from my career there. I also speak frequently at compliance conferences and other events, and will pretty much shoot the breeze on any compliance topic with anyone who asks.

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