General
Tips on Reporting to the Board
The other week I had the good fortune to moderate a webinar on how compliance officers can have a better relationship with the board of directors, which is a top priority for pretty much all of you. The conversation was great and the advice excellent, so I took plenty of notes and now pass them…
Read MoreTips on Navigating Ethical Dilemmas
Earlier this week I attended the annual conference of the Association of Certified Fraud Examiners, where some 4,000 people gathered to talk all things fraud and how to prevent it. Several sessions, however, looked at the larger issue of the ethical dilemmas employees often face when encountering examples of fraud. Let’s pull on that thread.…
Read MoreExample of Cyber Disclosure Challenges
Radical Compliance is back from vacation, and what better way to catch up on current compliance issues than an enforcement action over poor cybersecurity? Lucky for us, the Securities and Exchange Commission served up a fresh case just last week on exactly that headache. The case involves R.R. Donnelley, provider of business marketing services to…
Read MoreArchives, 2022: CCO Certifications
Radical Compliance is taking an off-the-grid vacation for the next few days, so we are reprinting some of readers’ favorite posts from the archives. The following ran in August 2022. 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…
Read MoreArchives, 2019: A Good FCPA Settlement
Radical Compliance is taking an off-the-grid vacation for the next 10 days, so we are reprinting some of readers’ favorite posts from the archives. The following ran in February 2019. Now that we’ve had a long weekend to digest the FCPA enforcement action imposed against Cognizant Technologies last week, compliance officers have a lot more…
Read MoreCompliance Jobs Report: June 14
We have a somewhat abbreviated Compliance Jobs Report this week since Radical Compliance is on vacation, but still lots of news: a new gig for the former CCO at Google; other appointments at Rogers Communications, Bristol Myers Squibb, and elsewhere; and job leads in energy trading, biotech, and motorcycle purchases. Plus our Meme of the…
Read MoreArchives, 2017: Mittens and Manual Controls
Radical Compliance is taking an off-the-grid vacation for the next 10 days, so we are reprinting some of readers’ favorite posts from the archives. The following ran in November 2017. Here at the Radical Compliance home office, every morning my job is to rouse my toddler son from bed, make him breakfast, and take him…
Read MoreAn Accountability Model for AI
Who’s looking for another thoughtful speech about the compliance implications of artificial intelligence? Because we have one from a top banking regulator in the United States, who raises deep issues about AI that go well beyond the banking sector. The speech comes from Michael Hsu, head of the Office of the Comptroller of the Currency,…
Read MoreNotes on Effective Internal Controls
Last week I had the chance to moderate a webinar on an issue eternally flummoxing to compliance officers: building effective systems of internal control. We had great speakers who gave great advice, so as usual I took lots of notes to pass along to the rest of you here. Let’s first appreciate why internal controls…
Read MoreMore on Cooperating With Regulators
Cooperation with regulators is a primary message from the regulatory enforcement world these days. So let’s see what a senior SEC official had to say on the subject lately and what compliance professionals can do to anticipate those cooperation needs. The official in question is Gurbir Grewal, head of the Enforcement Division at the Securities…
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