Five Post-Election Points for CCOs to Ponder

By Matt Kelly | November 9, 2016

Well, the American people, in their endless wisdom or lack thereof, elected Donald Trump to the White House and gave us a Congress even more deeply divided than before. The post-mortems on what happened last night and what it means for the country will be many, and last for months. Compliance officers can get started…

Lessons and Questions From AgBank Sanction

By Matt Kelly | November 8, 2016

Last week New York state regulators fined Agricultural Bank of China $215 million for running a weak compliance program and undermining its chief compliance officer so much that eventually she quit. Sounds great, right? Well, before you go stapling that piece of news to your audit committee chairman’s forehead, let’s take a closer look at…

Lessons on Institutional Lying From the Army

By Matt Kelly | November 7, 2016

Employees paying lip service to compliance is rampant at large organizations. They lie about completing training as required, about audits performed or procedures done, just so the documentation looks good and the compliance officer goes away. We all know this. So I was delighted recently to find a study from that largest of large organizations,…

Compliance Officers on the Move: Nov. 4

By Matt Kelly | November 4, 2016

This week’s jobs news in compliance includes several new CCOs in the financial sector, Johnson Controls’ head of EMEA compliance making a move, and the return of an early GRC entrepreneur back to the field after several years away. For all the good stuff, read on. I gather these bits of gossip from LinkedIn, news alerts,…

Finding the ‘Right’ Compliance Budget for You

By Matt Kelly | November 2, 2016

The other day a compliance officer in the Middle East asked me a question: how much money should a company spend on compliance as a percentage of its annual budget? Or, my friend added, should you define that benchmark as a percentage of annual revenue, or margin, or outlays for employees, or what? How can…

Three Points to Prepare for Non-GAAP

By Matt Kelly | October 31, 2016

Just in time for fourth-quarter audit committee meetings, everyone’s favorite financial reporting punching bag for 2016 is back: non-GAAP financial metrics! When we last visited non-GAAP metrics in July, the chatter against this quasi-scourge was rising. The SEC didn’t like it, the PCAOB didn’t like it, governance activists didn’t like it. Then everyone seemed to…

Compliance Officers on the Move: Oct. 28

By Matt Kelly | October 28, 2016

Lots of jobs news in compliance this week! We have a compliance officer meltdown at Broward Health, a new head of European compliance for McDonald’s, a new head of American compliance for Takata, and more beyond that. I gather these bits of gossip from LinkedIn, news alerts, and friends emailing me something to include. If you…

Best Practices in SOX Certifications

By Matt Kelly | October 27, 2016

Some shameless self-promotion today: I have a guest post on Workiva’s blog about financial reporting and SOX compliance, exploring a few best practices in how companies can design and operate certification programs for SOX controls. Getting control owners to certify the effectiveness of those controls is not a new idea, I know. (I first wrote…

SEC Just Put Pre-taliation Risk Front & Center

By Matt Kelly | October 25, 2016

The SEC said this week that it will begin looking for signs of pre-taliation risks during routine examinations of registered investment advisers—the clearest sign yet that pre-taliation risk is here to stay, and that the SEC takes a serious, expansive view of the subject. Word of the SEC’s intentions came in an alert released Monday…

ERM Framework: Govt. Sector Calls for Unity

By Matt Kelly | October 24, 2016

One of the sleeper issues this year, that could become a larger issue for risk and compliance officers next year, is the COSO draft framework for enterprise risk management. Compliance officers in the private sector might want to watch what your brethren in the government sector are saying about ERM, since the points they are raising…