control environment

A Fresh Example of Poor Control Environment

By Matt Kelly | September 5, 2024

The Securities and Exchange Commission has charged a Massachusetts company with allowing a poor control environment and weak segregation of duties, which in turn allowed one of the company’s corporate finance directors to inflate his division’s financial performance for years. The company in question is Circor International, a maker of industrial valve systems for the…

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RTX

RTX, Part II: The Compliance Reforms

By Matt Kelly | September 3, 2024

Today we continue our look at that RTX Corp. export controls settlement announced last week, since we barely scratched the surface of the remediation measures RTX agreed to undertake. From dedicated compliance leaders to dedicated compliance spending, there’s lots more to review here. If you missed our previous post on the case, the summary is…

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rtx

RTX Settles Huge Export Controls Mess

By Matt Kelly | September 2, 2024

Anyone looking for a complicated case-study in export controls compliance, turn your eyes to RTX Corp. The defense contracting giant just agreed to pay $200 million and overhaul its export compliance function, to settle charges that the company improperly sent classified defense goods to foreign countries and allowed employees to bring along sensitive information while…

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compliance jobs

Compliance Jobs Report: Aug. 30

By Matt Kelly | August 30, 2024

Another big Compliance Jobs Report heading into Labor Day Weekend! We have new hires at Eli Lilly, Veon, Truist, Lifepoint Health, and more; plus a reshuffle of integrity and compliance leaders at Volkswagen. Also a bunch of promotions to note, job leads in insurance, investing, and hospitality; and Meme of the Week goes out to…

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declination

BCG Scores FCPA Declination

By Matt Kelly | August 29, 2024

The Justice Department has decided not to bring FCPA charges against Boston Consulting Group, crediting the firm for its prompt self-disclosure of bribery problems in Africa and for the painful financial consequences it imposed on the offending employees. Let’s dig into the declination letter and see what lessons the rest of the corporate compliance community…

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whistleblower

A Telling SEC Whistleblower Award

By Matt Kelly | August 27, 2024

Another week, another tantalizing whistleblower award from the Securities and Exchange Commission! This time around, the agency has doled out $20 million to some senior corporate officer who first tried to get the company to investigate a misconduct allegation internally, and then went to the SEC when the company took no action. The SEC announced…

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Disney

Keeping Compliance & Legal Separate

By Matt Kelly | August 26, 2024

Last week we had a popular post about why ethics and compliance officers don’t necessarily need to be lawyers to do a good job. Now we have a vivid example of why the entire ethics and compliance function should be separate from legal, courtesy of a debacle at Disney over a wrongful death lawsuit. You…

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Compliance jobs

Compliance Jobs Report: Aug. 23

By Matt Kelly | August 23, 2024

The Compliance Jobs Report this week has updates from MKS Instruments, Bally’s, Barclays, Avient, Cintas, and more. We have a slew of promotions to note; job leads in television, cancer treatment, and FCPA enforcement; and Meme of the Week goes out to target shooters! Always remember that we need your help to make the Report…

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Undermining

Undermining the CCO, Part II

By Matt Kelly | August 22, 2024

Earlier this month we had a popular post on ways that senior management might undermine the chief compliance officer’s power and authority. The post sparked quite a bit of feedback, so today let’s share more stories of management undermining the CCO — and ways the CCO could try to push back. The original post identified…

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cybersecurity

More Lessons on Cyber Control Failures

By Matt Kelly | August 21, 2024

We have another glimpse into modern cybersecurity threats and the control weaknesses that allow those threats to happen, courtesy of an enforcement action against a financial services firm that twice was duped by hackers into selling their customers’ assets.  The financial services firm is Equiniti Trust Co., a registered transfer agent — that is, a…

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