More on Auditors and Compliance Violations


Today let’s return to that proposal to have audit firms look more aggressively for compliance and legal violations at their client companies. One of  my spies in the audit world recently provided me a glimpse into his firm’s preliminary discussions about this idea — and their concerns are well worth compliance and internal audit professionals’…

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Random Thoughts on Ethics & Compliance


We’re still digging out from vacation last week, and working from Europe this week while attending a major internal auditing conference. To stall for time, then, we have another edition of random thoughts on all things related to audit, risk, and compliance, plus whatever else comes to mind. Without further delay…  Can we talk once…

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On 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, July 7. You can always send us tips at [email protected]. Otherwise, behave yourselves and we’ll be back as usual on Monday, July 10.

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Is Cyber Driving the CCO-Board Relationship?


We begin this week with yet another compliance benchmarking report, this time from Navex: a deep look at how compliance officers engage with senior management, and whether cybersecurity concerns, rather than anti-corruption, might be driving the board’s attention to compliance these days.  Navex published the report late last week. It polled more than 1,300 compliance…

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Notes on Compliance Hotline Analytics


Today I want to return to that compliance program benchmarking survey released last week by KPMG and White & Case. The report includes several findings about how companies handle their internal whistleblower hotlines that warrant our attention, given how important the hotline can be to your overall culture of compliance.  Essentially, the findings are these:…

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An Internal Governance Basket Case


Talk about the gang that couldn’t shoot straight: One of the largest online gun marketplaces in the United States just filed its latest annual report, and the thing is an internal controls and corporate governance catastrophe. If you’ve ever needed an example of how not to manage your governance operations, read onward. The company in…

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PCAOB and Compliance Violations, Part II


Today I want to revisit last week’s proposal from the Public Company Accounting Oversight Board that audit firms should look more aggressively for compliance and legal violations at their client companies. There are compelling arguments about why this might be a bad idea, which compliance and internal audit professionals need to consider closely. To understand…

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Notes on Good Compliance Training


Compliance professionals often use the words “training” and “communications” mushed together to represent one component of your compliance program. That’s not really true, however; training and communications are complementary concepts, and compliance officers need to appreciate that distinction if we want each one to support the other.  That insight came to me the other week…

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Working With Middle Managers

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…

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A 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…

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