General
FDIC, Part III: How Leadership Fell Short
We have yet another thread to pull from the Federal Deposit Insurance Corp., and the corporate culture debacle there that led FDIC chairman Martin Gruenberg to announce his resignation last week. Specifically, what shortcomings in Gruenberg’s leadership style may have contributed to the FDIC’s culture going so far astray? As we’ve explored in previous posts,…
Read MorePodcast: Do DPAs Really Work?
Today we have another Radical Compliance podcast, trying to unpack a question near to the hearts of compliance professionals everywhere: Do deferred-prosecution agreements really work to improve corporate behavior? This issue has been on my mind lately because federal prosecutors recently accused Boeing of breaching the DPA it struck in 2021 to settle criminal charges…
Read MoreFDIC, Part II: Lack of Accountability
Today let’s return to the Federal Deposit Insurance Corp., and the corporate culture meltdown documented in an investigative report the FDIC released last week. Specifically, let’s look at the lack of accountability even amid years of misconduct, and how that sorry state of affairs came to pass. For those who haven’t heard yet, last week…
Read MoreStating Your Ethical AI Principles
Today we have another chapter in our ongoing series about artificial intelligence, and how companies can take a more compliance-aware approach to integrating AI into their operations. This time around I want to look at what the companies themselves are disclosing to the public. The idea came to me as I was researching my previous…
Read MoreTracking Local Compliance Associations
Radical Compliance strives to be a community resource for compliance professionals everywhere, so today we are looking at local groups of compliance officers who get together for networking. Are you part of a group that should be on this list? We have had a running list of local compliance associations for several years, although the…
Read MoreWhat Boards Are Saying About AI
Today I want to start an occasional series about artificial intelligence, and how businesses can take a more risk- and compliance-aware approach to integrating AI into their operations. We might as well start that exploration at the top: What are boards saying about how they oversee the adoption of artificial intelligence? Not much, apparently. At…
Read MoreHow to Support Policy & Procedure
The New York Times had a fascinating article last week about discrimination in hiring practices at large corporations. The article also cited a powerful remedy for discriminatory hiring practices — one that compliance officers might want to ponder at length, for what it tells us about effective compliance generally. Let’s start with the article itself,…
Read MoreAdvice on the Art of Risk Assessments
Risk assessments can be a dizzying challenge for compliance officers, with so many ways to approach the task and so many variables to consider. So today let’s review some of the big themes from a webinar on risk assessments that I moderated last week, where plenty of good advice was dished out. We spent a…
Read MoreThe Frustration of CCO Job Searches
Today let’s pivot back to the job market for compliance professionals, to dissect a hiring habit that I suspect drives you all absolutely nuts: general counsels mucking around with compliance officer job descriptions and personnel plans when those folks don’t really know what they’re talking about. Compliance officers tell me these tales of derailment in…
Read MoreAnother FCPA Action With No Monitor
Another week, another FCPA enforcement action against a Swiss commodities trader — and one that again might leave compliance officers puzzled, since it involves a repeat corporate offender that didn’t self-disclose, yet still managed to walk away without a compliance monitor. The company in question is Trafigura, which last week pleaded guilty to charges that…
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