Turning Around Compliance Programs

program

Most compliance officers will at some point in their careers find themselves needing to turn around an under-performing corporate compliance program. So today we have another Radical Compliance podcast interview, this time with a compliance officer who styles himself as a “turn-around specialist.” He had plenty to say about how to get under-performing programs back…

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Optimizing the Right Compliance Vector

compliance

A compliance officer should always be ready to take a good idea wherever you find it and figure out how it might improve your compliance program. In that spirit, today let’s talk about a nifty phrase I stumbled across in the technology world that could help compliance officers immeasurably in these tumultuous days: finding “the…

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Rebutting Resistance to Compliance Investments

compliance

Earlier this week I visited one of the larger compliance vendors in the market to talk with their sales staff about the pressures compliance officers face. Our discussion quickly centered on two questions. First, why do some companies decide not to invest in compliance capabilities? And second, what are some possible arguments that might change…

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Metrics for Assessing AML Compliance Program

AML

Financial crimes compliance is not easy, and that’s especially true for fintech firms — young, fast growing, and subject to a complicated thicket of anti-money laundering rules. Building an effective compliance program in that environment is not easy, and compliance officers need to tread carefully to get it right. To that end, in this post…

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Compliance Program Priorities That Endure

compliance

’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…

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Special Report: Compliance Testing, Data Access Falls Short

testing

An exclusive new report finds that most corporate compliance teams struggle to perform adequate testing and monitoring of their compliance programs, and also struggle to get access to the enterprise data they need to address their organizations’ compliance risks effectively. Those are just some of the findings of a study released this week by Rethink…

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Concerns Over Access to Data

data

Today let’s return to the Justice Department’s newly revised guidance for effective corporate compliance programs. Specifically, let’s give a close analysis of what those updates say about compliance officers’ access to data and IT systems.  For starters we should appreciate why access to data is such an important issue for the Justice Department at all.…

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Revamped Compliance Program Guidance!

Justice

The Justice Department is rolling out fresh guidance for how it evaluates corporate compliance programs, with new sections addressing artificial intelligence, a company’s speakup culture, and whether compliance teams have sufficient access to the data they need to keep their programs on the right path. The head of the department’s Criminal Division, Nicole Argentieri, announced…

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RTX, Part II: The Compliance Reforms

RTX

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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Keeping Compliance & Legal Separate

Disney

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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