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,…

Read More
Compliance jobs

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,…

Read More

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…

Read More

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…

Read More
Compliance jobs

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…

Read More

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…

Read More

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…

Read More
erm framework

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…

Read More
Compliance jobs

Compliance Officers on the Move: Oct. 21

By Matt Kelly | October 21, 2016 |

The big compliance jobs gossip this week is the retirement of Citigroup’s chief compliance officer. We also have new appointments at the SEC, a bunch of investment firms, and food maker JBS. Lots going on for the week ending Oct. 21. I gather these bits of gossip from LinkedIn, news alerts, and friends emailing me something…

Read More
salary

Of SOX Controls and Earnings Reports

By Matt Kelly | October 20, 2016 |

The data analytics gurus over at Calcbench just published some numbers that SOX compliance and SEC reporting professionals might find interesting: a study of the gap between publishing an earnings release and filing the subsequent quarterly report. Calcbench reviewed the Form 8-K earnings releases and Form 10-Q quarterly reports from 3,399 companies that filed in…

Read More

About Us

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.