Posts Tagged ‘compliance programs’
Deep Dive Into DOJ Compliance Guidance
Last week the Justice Department released new guidance on effective corporate compliance programs, to incorporate the department’s new stance on compensation clawbacks and disciplinary procedures that it wants companies to embrace. Let’s take a close read of those changes to see what’s going on. The updated guidance comes after numerous speeches by Justice Department officials…
Read MorePointers on Data Analytics
The other day I had the good fortune to moderate a webinar on data analytics in the compliance function. Considering the pressure corporate compliance programs are now under to develop strong analytics capability, let’s review some of the main points and themes that emerged from the discussion. For starters, compliance officers should take another look…
Read MoreCompliance Program Benchmark Surveys!
Who doesn’t love a good survey report on compliance officers and the challenges they face? This week we have two worth your time, with observations both great and small that compliance officers can use as you ponder how to strengthen your own compliance programs. Our first study comes from LRN, which last week published its…
Read MoreDanske Bank, Part II: Compliance Reforms
Today let’s continue to look at the settlement Danske Bank reached with the Justice Department earlier this week, for the huge money-laundering scheme that operated from the bank’s Estonia branch in the 2000s and 2010s. I’ve been reading the plea agreement in the case, and compliance officers have a lot to consider here. First, to…
Read MoreWisdom From a Compliance Dinosaur
The other week I had coffee with a veteran compliance officer passing through town. This CCO has worked at numerous global organizations, some of the biggest names in his industry and to the public at large. So when my friend — we’ll call him the Dinosaur, since that’s how he described himself — started talking…
Read MoreI Talked Compliance With BlenderBot
Everyone knows I’ll talk ethics and compliance with just about anybody. So when Facebook decided to roll out its new AI-driven chatbox, of course I swung by its website and started asking the bot what it thought of corporate compliance programs. The bot, apparently named BlenderBot 3, was launched on Monday. People can strike up…
Read More‘Reasonably Designed’ Programs, Part II
Our post last week about the lack of clear standards for a “reasonably designed” compliance program drew lots of comment from compliance professionals — enough that the issue deserves continued exploration, since there’s plenty more to say on the subject. First let’s consider a concrete example of the confusion that could arise here. Imagine your…
Read MoreLessons From Glencore Settlement
Earlier this week Swiss commodities trading giant Glencore gave the compliance community a doozy of a corporate corruption settlement, agreeing to pay more than $1 billion to regulators around the world for bribery and market manipulation that lasted more than a decade. I’ve been sifting through the settlement documents since then and we have several…
Read MoreSome Polite Words on Testing
Gather round, corporate compliance professionals. We have another speech from a high-ranking Justice Department official about how compliance programs should work, and as usual these days, the speech is full of clues that are well worth your time and attention. The speech came from Kenneth Polite, assistant attorney general for the Criminal Division, who spoke…
Read MoreComEd, Part II: Tone From Top, Enforcement
Today I want to return to Commonwealth Edison, the Illinois public utility trying to revamp its corporate culture and compliance program after a corruption scandal that erupted in 2020. As we sift through ComEd’s progress report on improvements it has made, let’s examine two subjects indispensable to effective compliance programs: tone at the top and…
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