Musings on Messaging Apps

waivers

Compliance officers have a lot to ponder in the Justice Department’s recent updates to its guidance for corporate compliance programs. The most demanding issue, however, might be how the department wants companies to handle employees’ use of messaging apps. It’s going to be quite the challenge. Clearly messaging apps are a priority for the Justice…

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Suggestions for Small Compliance Programs

small

At some point in their careers, most compliance officers will spend time working at or running a small compliance program. So when I had the chance earlier this month to moderate a webinar on that subject, I took detailed notes. I suspect many of the frustrations and issues voiced by those small-company compliance officers will…

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Deep Dive Into DOJ Compliance Guidance

guidance

Last week the Justice Department released new guidance on effective corporate compliance programs, to incorporate the department’s new stance on compensation clawbacks and disciplinary procedures that it wants companies to embrace. Let’s take a close read of those changes to see what’s going on. The updated guidance comes after numerous speeches by Justice Department officials…

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Pointers on Data Analytics

analytics

The other day I had the good fortune to moderate a webinar on data analytics in the compliance function. Considering the pressure corporate compliance programs are now under to develop strong analytics capability, let’s review some of the main points and themes that emerged from the discussion. For starters, compliance officers should take another look…

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Compliance Program Benchmark Surveys!

survey

Who doesn’t love a good survey report on compliance officers and the challenges they face? This week we have two worth your time, with observations both great and small that compliance officers can use as you ponder how to strengthen your own compliance programs.  Our first study comes from LRN, which last week published its…

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Danske Bank, Part II: Compliance Reforms

compliance

Today let’s continue to look at the settlement Danske Bank reached with the Justice Department earlier this week, for the huge money-laundering scheme that operated from the bank’s Estonia branch in the 2000s and 2010s. I’ve been reading the plea agreement in the case, and compliance officers have a lot to consider here.  First, to…

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Wisdom From a Compliance Dinosaur

dinosaur

The other week I had coffee with a veteran compliance officer passing through town. This CCO has worked at numerous global organizations, some of the biggest names in his industry and to the public at large. So when my friend — we’ll call him the Dinosaur, since that’s how he described himself — started talking…

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I Talked Compliance With BlenderBot

AI

Everyone knows I’ll talk ethics and compliance with just about anybody. So when Facebook decided to roll out its new AI-driven chatbox, of course I swung by its website and started asking the bot what it thought of corporate compliance programs.  The bot, apparently named BlenderBot 3, was launched on Monday. People can strike up…

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‘Reasonably Designed’ Programs, Part II

reasonably

Our post last week about the lack of clear standards for a “reasonably designed” compliance program drew lots of comment from compliance professionals — enough that the issue deserves continued exploration, since there’s plenty more to say on the subject.  First let’s consider a concrete example of the confusion that could arise here.  Imagine your…

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Lessons From Glencore Settlement

Glencore

Earlier this week Swiss commodities trading giant Glencore gave the compliance community a doozy of a corporate corruption settlement, agreeing to pay more than $1 billion to regulators around the world for bribery and market manipulation that lasted more than a decade. I’ve been sifting through the settlement documents since then and we have several…

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