Crazy Compliance Officer News

compliance officer

Sometimes there is simply too much news happening in the compliance world, and today is one of those times. So rather than take a deep dive into a specific subject, we’re going to run through several newsworthy items that have streaked across the radar screen in the last few days. First we should start with…

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Thoughts on Training and CCO Certifications

training

So there I was the other day, talking with a compliance officer who helps with training at a large global corporation. We were chatting about a fairly common question in the field: should companies allow people to test out of compliance training if they already know the subject matter?  That’s a complicated question unto itself,…

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Speakup Lessons From U.S. Army

Army

Compliance professionals are constantly looking for ways to improve the speakup culture in their organizations. Today let’s look at an example of how difficult that task can be, courtesy of the U.S. Army and a recent audit of its efforts to encourage reporting of sexual assaults. The Government Accountability Office performed the audit and published…

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Thoughts on the Uvalde Failures

Uvalde

Effective corporate compliance and risk management programs are all about how to make a large organization run well. So within that frame, the school shooting in Uvalde, Texas, last week is an awful, heartbreaking case study for corporate compliance programs, because we can find failures at almost every level.  Indeed, what torments me most about…

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FDA’s Lessons on Internal Reporting

internal reporting

Aside from all the FCPA news that’s been happening lately, compliance officers also have a cautionary tale to consider this week about internal reporting. We have the fiasco of the Food & Drug Administration and a whistleblower trying to raise alarms about poor conditions at Abbott Nutrition’s infant formula manufacturing plant in Michigan. The Washington…

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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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Some Polite Words on Testing

fcpa

Gather round, corporate compliance professionals. We have another speech from a high-ranking Justice Department official about how compliance programs should work, and as usual these days, the speech is full of clues that are well worth your time and attention. The speech came from Kenneth Polite, assistant attorney general for the Criminal Division, who spoke…

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Some Thoughts on IT Workforce Risks

Looking for another reason to worry about the long-term success of your compliance, audit, or risk management efforts? Fear not! A recent report on workforce development in cybersecurity paints a stark picture of just how challenging it is these days to build and maintain a good team.  The report comes from ISACA, the professional association…

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Tips on Whistleblower Tips

whistleblower

I had the good fortune this week to attend a panel discussion on the latest developments in whistleblower tips and SEC enforcement. Given how often whistleblower tips turn into big, complicated headaches for corporate compliance officers, let me pass along some insightful morsels from the speakers.  The panel was part of the day-long Securities Enforcement…

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ComEd, Part II: Tone From Top, Enforcement

ComEd

Today I want to return to Commonwealth Edison, the Illinois public utility trying to revamp its corporate culture and compliance program after a corruption scandal that erupted in 2020. As we sift through ComEd’s progress report on improvements it has made, let’s examine two subjects indispensable to effective compliance programs: tone at the top and…

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