‘Reasonably Designed’ Programs, Part II


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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Compliance Jobs Report: Aug. 5

compliance jobs

Following this morning’s monster jobs report for the U.S. economy, the Compliance Jobs Report has its own brisk update for this week too! We have items to report from Blackstone, Walmart, Fifth Third Bank, Alexion Pharmaceuticals, and many more. Job leads in banking, software sales, and stock trading; and our Meme of the Week goes…

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‘Reasonable Design’ and CCO Certifications


Today I want to revisit the Justice Department’s plans to have chief compliance officers certify the effectiveness of their compliance programs, to unpack a question that’s been bothering me. When the department says it wants certification that your program is reasonably designed to prevent future violations, what does “reasonable” actually mean?  Readers of Radical Compliance…

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Robinhood Crypto Compliance Meltdown


New York financial regulators have issued a scorcher of an enforcement action against Robinhood, hitting the online trading app with a $30 million for allowing a weak compliance program that, in turn, allowed a wide range of other compliance failures. The New York Department of Financial Services (DFS) announced the sanction on Tuesday. The precise…

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On Wisconsin and Cyber Risks


IT audit professionals looking for a fresh example of cybersecurity risk to study should turn their gaze to Wisconsin. A voter fraud conspiracy theorist there uncovered what is indeed a legitimate risk to election integrity, and his discovery speaks volumes about taking a risk-based approach to design of internal controls. The gadfly in question is…

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Fresh Lessons on Management Fraudsters


One of the largest PR firms in the world is going through its own minor PR crisis this week, with its former CFO pleading guilty to embezzling $16 million from the firm over the course of nearly a decade.  Frank Okunak, who ran financial operations at PR firm Weber Shandwick from 2009 to 2019, pleaded…

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Compliance Jobs Report: July 29

compliance jobs

The Compliance Jobs Report this week has several hires at Freddie Mac; several departures from fintech firm Revolut; and other personnel news from Clear Channel, Western Union, Teleflex, FanDuel, and elsewhere. Job leads this week are in makeup, banking, and social services, all in New York City; and Meme of the Week goes out to…

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CCO Compensation Up 9 Pct


Attention, all you compliance officers negotiating a new pay package! We have a fresh CCO compensation survey that says average salary and bonus are at $430,000 this year, up 9 percent from 2020 levels.  Recruitment firm Major, Lindsey & Africa published the compensation report today. Much of the data relates to general counsels and other…

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Lessons in Cardiac Company Fraud Settlement


A medical device company based in Oregon has agreed to pay $12.95 million to settle charges that it ran a sham training program as a vehicle to pay kickbacks to doctors, in a case that offers compliance professionals plenty of lessons about internal controls and third-party risk. The company is Biotronik, a maker of defibrillators,…

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Pointers on Preventing Ransomware 


Among the many interesting discussions I heard at the Institute of Internal Auditors’ global conference this week, one particularly compelling session was about ransomware: how attackers try to foist it upon companies, and the internal controls you could implement to keep such attacks at bay. Since ransomware risk is going nowhere but up these days,…

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