General
Working With Middle Managers
The other week I had the good fortune to moderate a webinar on how compliance officers can work with middle management — those assistant vice presidents, department heads, regional managers, and other executives so crucial to the success of a corporate compliance program. I took lots of notes, and pass them along now since this…
Read MoreA Messaging Violation in Detail
Amid all the consternation these days about employees’ improper use of messaging apps, how did we overlook this? An enforcement action from FINRA earlier this year over a financial firm’s mishandling of iMessages, which happens to offer a fascinating glimpse of the control failures that can happen here. The firm in question is Deloitte Corporate…
Read MoreMore Dreary News on Messaging Apps
A new survey of compliance officers finds most of them with grave doubts about their company’s ability to police against employees’ improper use of messaging apps, and are enacting bans mostly as gestures to demonstrate their effort at compliance obligations — but few believe such bans actually work. So says a report from Global Relay,…
Read MoreThoughts on Developing an ESG Program
Today I want to circle back to that KPMG survey of compliance officers that the firm released two weeks ago. We have another issue in that report worth our attention: corporations’ efforts to stand up ESG programs, and the role that compliance officers might play. The report, which surveyed 240 chief compliance officers at large…
Read MoreMy ChatGPT Compliance Misadventure
Today I want to relay a dispatch from the front lines of artificial intelligence and corporate compliance. Namely, I’ve been trying to use ChatGPT for a compliance project, and ChatGPT has pretty much made a mess of things. The project itself is straightforward. A client has asked me to find the texts of whistleblower laws…
Read MoreA Survey on Compliance IT Issues
KPMG published a survey last week that delivers news both good and bad for compliance officers. Spending on staff and technology are likely to increase in the next year (yay!) — but compliance functions are also under more pressure, primarily from boards and regulators, to do better (boo!). The survey polled 240 chief compliance officers…
Read MoreCorporate Culture & the Ted Lasso Way
There is a sub-culture of compliance professionals out there who adore “Ted Lasso,” the Apple TV drama about an American football coach leading a British soccer team. I have delightful news for this crowd: the most recent episode included a scene about Ted’s coaching style that speak perfectly to how a corporate culture should work.…
Read MoreCompliance Job Market: One Person’s Tale
I had a phone call the other day with my friend the Job Applicant. This person is looking for a senior-level compliance officer position, and having a rough go of it lately. Their experiences are telling about the compliance job market today, so with the Job Applicant’s permission, I am sharing them here. First, let…
Read MoreA Closer Look at ICSR Reporting
Today I want to revisit sustainability reporting, and the recent guidance from COSO on designing effective internal control for sustainability reporting. Compliance officers, auditors, and corporate sustainability teams have much more to consider here to get “ICSR” at your company right. We can begin with the most basic question of all: Why is any of…
Read MoreSome Compliance Principles for ChatGPT
The other week I moderated a webinar on ChatGPT’s implications for corporate compliance programs. ChatGPT itself was not invited to participate, but no worries: we humans on the webinar had plenty to say about its compliance risks all by ourselves. Those worries are well-founded. ChatGPT and its ilk have taken the technology world by storm…
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