Insights From Navex Benchmarking Report

Navex Global has published its latest annual ethics & compliance benchmarking report, a deep dive into all sorts of activities and priorities among corporate compliance programs. It’s a great document to help compliance officers place their own issues in larger context, so let’s take a look at what Navex had to say. Typically Navex publishes…

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Interesting Action From OFAC


Compliance officers might want to take a close look at the wrist-slap that State Street Corp. received from the Office of Foreign Assets Control on Tuesday, for violations of sanctions against Iran. It’s a small but telling example of how a robust compliance program brings benefits, OFAC or otherwise. OFAC did cite State Street for…

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PwC 2018 State of Compliance Report

PwC released its annual State of Compliance survey on Tuesday, and let’s start with the angst: most compliance officers aren’t confident that their companies’ compliance programs are effective. Of the 825 professionals surveyed, only 17 percent said they are “very satisfied” with the effectiveness of their compliance programs. About 45 percent say they are somewhat…

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Compliance While Cutting Middle Management


Compliance officers deal with corporate restructurings all the time, including the occasional craze of cutting middle management — “flattening the structure to allow better decision-making” or some CEO-speak like that, when really the company wants to cut spending by cutting heads. As short-sighted moves to cover up bad strategic leadership go, culling middle managers is…

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Deeper Dive Into New DoJ Compliance Guidance

compliance guidance

Yesterday I did another “Compliance in the Weeds” podcast with Tom Fox, where our subject of conversation were the Justice Department’s new guidelines for evaluating corporate compliance programs. That guidance—46 questions that prosecutors might ask about your compliance program, across 11 broad categories—is manna from heaven for corporate compliance officers. The questions are specific. They…

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