General
Ohio State, Part II: Documentation Lessons
Today we return to Ohio State University and the recent resignation of its president for steering university resources toward an affair partner. Compliance professionals have lots to learn from how Ohio State handled the matter, including this: the importance of strong documentation policies. For those who need a quick recap, Ohio State president Ted Carter…
Read MoreJeffrey Epstein and Third-Party Risk
Later this week I’ll be speaking on a webinar about lessons in third-party risk that compliance officers can learn from the Jeffrey Epstein debacle. At first I wondered how much an Epstein discussion would resonate with compliance officers. Does his uniquely awful story really offer many useful lessons for people who run corporate compliance programs? …
Read MoreOn Vacation This Week
Thank you for visiting, dear readers, but Radical Compliance is taking some much-needed vacation this week. We likely won’t have any updates to the website, and no newsletter on Friday, April 24. You can always send us tips at [email protected]. Otherwise, behave yourselves and we’ll be back as usual on Monday, April 27.
Read MoreFrom CCO Alone to Proving Value
My previous post in Radical Compliance explored the isolation that chief compliance officers so often feel in their jobs, how isolation is not the independence that compliance officers do need, and why isolation can be so corrosive to corporate success. The response to that first column — from compliance officers, risk leaders, attorneys, and executives…
Read MoreMaking Enforcement & Accountability Work
Last week I moderated a webinar on the Justice Department’s new corporate enforcement policy. It gave us an excellent opportunity to unpack the overlapping issues facing compliance officers, from enforcing individual accountability to supporting a strong speakup culture to performing effective root cause analysis. I took lots of notes as usual, and pass them along…
Read MoreLaunching: The CCO Retaliation Survey
One of the top concerns for corporate compliance professionals has always been to protect employees from retaliation for speaking up about corporate misconduct. Today Radical Compliance wants to flip that script by looking at something that, honestly, I’m astonished nobody has examined before: how often compliance officers themselves suffer retaliation for speaking up. We are…
Read MoreThe Challenges of Embracing Accountability
So there I was the other day, chatting on a webinar about current compliance issues, and conversation turned to the Justice Department’s push to hold individual wrongdoers accountable for corporate misconduct. I thought was a fairly straightforward idea, until a listener offered a comment that stopped me short. “Accountability is a big conversation happening at…
Read MoreYes, the Compliance Officer Stands Alone
If you’re a compliance officer or have ever been one, there’s a good chance you have felt it: that particular friction. The sense that while you might be operating in the same organization as your C-suite peers, attending the same meetings, carrying the same title weight on paper — you somehow occupy a fundamentally different…
Read MoreMore on Vendor AI Risks
A compliance officer called me the other day to get my opinion on a question. If one of your technology vendors upgrades its systems to introduce artificial intelligence capabilities, and your employees immediately start using that AI-enhanced application with abandon, would that count as a violation of some policy against shadow AI that you might…
Read MoreNotes on AI and Vendor Risk
Third-party risk is never far from the chief compliance officer’s mind, so today let’s review a recent report on third-party risk management programs that spotlighted a few emerging issues — mostly around artificial intelligence, naturally — that are driving compliance officers up the wall. The report comes from Ncontracts, a firm that sells third-party risk…
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