General
The Joys of Pre-Acquisition Due Diligence
Few issues can exasperate a compliance officer as much as pre-acquisition due diligence for a business your company wants to acquire. So when I was moderating a webinar last week on compliance issues and conversation turned to that very subject, I took notes. What if, fellow compliance enthusiasts, there’s a better way to look at…
Read MoreCompliance Program Priorities That Endure
’Tis the season for speeches from Justice Department officials, as they reflect on the year’s enforcement activity — and these days, try to establish some sense of continuity even as the incoming Trump Administration portends a very different approach to corporate compliance and regulatory enforcement. Which brings us to a Justice Department speech delivered late…
Read MoreQuestions for Incoming SEC Chairman
Last week President-elect Trump said he will nominate Paul Atkins to be the next chairman of the Securities and Exchange Commission. Now compliance and audit professionals can start considering how an Atkins-led SEC will shape corporate compliance for the next few years, and there are lots of questions to contemplate here. Start with the biographical…
Read MoreFour Reasons to Watch the Adani Case
Sometimes a tale of corporate corruption comes along that perfectly captures all the issues that ethics and compliance professionals face in our line of work. Such is the case with the Adani Group, and compliance officers everywhere should watch it closely; it could be a hugely telling case for corruption enforcement in 2025. By now…
Read MoreThe DOGE Effect on Risk Management
Elon Musk and Vivek Ramaswamy shed more light this week on how they want their Department of Government Efficiency to operate. Their vision shows an alarming lack of understanding about how government operates, so compliance professionals should watch closely for the mess these two might make; you’ll be among the many stuck cleaning that mess…
Read MorePodcast: State of the Compliance Community
Today we have another Radical Compliance podcast, this time to talk about the community of ethics and compliance professionals and the challenges of keeping that community engaged. To unpack those issues I called up Gerry Zack, former CEO of the Society of Corporate Compliance & Ethics and the Healthcare Compliance Association. As compliance folks might…
Read MoreSome Reminders on Fraud Risk
Last week a former employee of Takeda Pharmaceuticals was sentenced to prison for a multi-million dollar embezzlement scheme against the company. The case is a good reminder that companies will always need strong internal accounting controls no matter what regulatory changes might happen in Washington, so let’s take a look. The ex-employee at the center…
Read MoreHow Boards Should Oversee Compliance
Compliance officers wonder constantly about how they should talk to the board of directors, and what issues they should bring to the board’s attention. Today let’s flip the script and ask — what should board directors be asking compliance officers? Which compliance issues should keep them awake at night? This is on my mind thanks…
Read MoreAn Update on TPRM Programs
A new survey finds that companies are — at long last — pushing their third-party risk management programs up the maturity curve, as they move from monitoring the cybersecurity risks among their vendors to actually reducing those risks. The report comes from BlueVoyant, a firm that helps businesses to manage their supply chain cybersecurity risks.…
Read MoreA Telling Move by CFPB
Compliance officers who want to skate where the puck is going to be, cast your eyes to the Consumer Financial Protection Bureau. Last week the agency warned companies to tread carefully when using artificial intelligence and other digital tracking to make employment decisions, and in doing so dropped two telling hints about the future of…
Read More