Compliance professionals in Boston looking to talk shop, you may want to consider an event happening later this month. Convercent will be hosting one of its Tech Talks on July 19, an excellent opportunity meet your peers, discuss the (many) technology challenges that face modern compliance programs, and enjoy a good meal to boot. The…
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Last week we looked at a recent federal appeals court ruling, Gilman v. Marsh McLennan, that affirms a considerable amount of power for compliance and legal officers conducting internal investigations. The decision has enough potential implications to warrant a follow-up post, so let’s keep going. I won’t rehash my earlier post here. Suffice to say…
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One of the big messages from regulators this year has been concern about companies’ use of non-GAAP financial metrics. Well, I’m happy to say that Radical Compliance has just released one of the first in-depth reports on the subject, trying to understand how widespread use of non-GAAP metrics really is and what drives companies to…
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COSO Chairman Robert Hirth visited Boston yesterday, speaking to the CAE Leadership Forum about COSO’s proposed new framework for enterprise risk management. I was lucky enough to attend and Hirth raises some excellent points about how COSO wants to help companies implement ERM, so let me recap the highlights here. First, we mentioned in this…
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A federal appeals court just gave compliance officers valuable insight into the limits of the Yates Memo—the Justice Department’s policy that if a company under investigation wants to win any credit for cooperation, it must turn over all information it can find about employees suspected of misconduct. The case, Gilman v. Marsh McLennan, is a…
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Last week I had a post about the SEC’s recent cybersecurity enforcement action against Morgan Stanley, examining the internal control failures that allowed a now-former employee to swipe the personal data of 730,000 customers. Well, if you’d like to consider that enforcement action from another angle, go read John Reed Stark’s excellent piece on what…
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Yesterday I had the good fortune to moderate a compliance forum on financial crime, hosted by RANE Network and Exiger. As you can imagine, anti-money laundering compliance is a huge concern for financial firms these days, so let me distill a few themes from the conversation here. Conflicting messages from regulators came up quite a…
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Sharpen your pencils, all enthusiasts of enterprise risk management: COSO has unveiled its new draft framework for ERM and is calling for public comment. The exposure draft is available on the COSO website, and the comment period runs from now until Sept. 30. This is COSO’s first update to the ERM framework, which it originally…
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Last week the Securities and Exchange Commission dinged Morgan Stanley $1 million for poor cybersecurity controls. The case is an excellent primer on policy management, compliance, and cybersecurity risks, so let’s take a look. The case centers on Morgan Stanley Smith Barney, one of the bank’s subsidiaries; and a financial adviser there named Galen Marsh.…
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Can we all just agree now that when they make the movie about FIFA corruption, we cast Dan Hedaya as Sepp Blatter?
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Technically, Radical Compliance is the personal blog of Matt Kelly, long-time writer and observer of the corporate compliance and GRC scene. I was a writer, editor, and publisher at Compliance Week, 2003 through 2015; some of you may know me from my career there. I also speak frequently at compliance conferences and other events, and will pretty much shoot the breeze on any compliance topic with anyone who asks.