Posts Tagged ‘compliance programs’
Keeping Compliance & Legal Separate
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…
Read MoreBoeing, Part II: The New Spending
Boeing reported second-quarter earnings today, which were predictably awful given the company’s safety and compliance lapses. So now seems like a good time to ponder the company’s recent promise to the Justice Department to increase spending on compliance efforts by $455 million over the next three years. What’s that all about? As you may recall,…
Read MoreA Look at Boeing’s Plea Agreement
Pull up a chair, compliance officers! We finally have a text of the Justice Department’s plea agreement with Boeing for the company’s violation of its 2021 deferred-prosecution agreement. Let’s see what the compliance team and senior management have promised to do to improve the company’s misbegotten corporate culture. The basic terms of the plea agreement,…
Read MoreDon’t Sweat Chevron’s End Either
So there I was, reading through the U.S. Supreme Court’s recent rulings, when the phone rang. On the other end was my friend the general counsel, who apparently had been doing the same. “Oh man,” he said, launching into a diatribe. “This ruling to overturn the Chevron doctrine is going to be a disaster for…
Read MoreSurvey: CCO Resources, Pressures Both Rising
KPMG has published a new survey of chief compliance officers with plenty of findings that the compliance community should find interesting. The good news is that most CCOs expect budgets and headcounts to rise in the coming year; the bad is that CCOs also expect more pressure for better compliance program performance from numerous directions. …
Read MoreMaking CCO-GC Relationships Work
As we all settle into the new year, let’s begin by continuing to debate an age-old question: What is the proper relationship among the chief compliance officer, the general counsel, and senior management? This has been on my mind since last month, when I moderated a webinar on new guidance for compliance officers in the…
Read MoreRemediation Efforts That Work
Before our fond memories of the Society of Corporate Compliance & Ethics 2023 conference sail into the sunset, I want to recap one more session I attended at the conference since it’s a subject well worth a compliance officer’s attention: the delicate art of remediating a compliance failure while you’re still investigating it. This has…
Read MoreReport: Insourcing Up, Confidence Too
Thomson Reuters has published a fascinating new survey of corporate compliance professionals, finding that most companies are bringing more risk management and compliance work in-house — and that a solid majority of compliance officers are confident that their teams can handle the compliance risks they face. That’s one major conclusion of the 2023 Thomson Reuters…
Read MoreThe Art of Compliance Program Assessment
One of the many sessions I attended at the Society of Ethics & Compliance conference last week was about how to perform an assessment of your compliance program. The discussion was great and I took lots of those notes. So today let’s run through those notes on this important task for compliance officers. We can…
Read MoreJustice Dept. Cuts Compliance Break for M&A
The Justice Department is extending yet another olive branch to companies to encourage stronger compliance programs, saying it typically will not prosecute companies that self-disclose issues at acquisition targets if the company makes that disclosure within six months of closing the deal. So said deputy attorney general Lisa Monaco on Wednesday, speaking at the Society…
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