Jane Lewis-Raymond

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The Compliance Version of Giving Tuesday, Cyber Monday, and Black Friday

There are a few things that compliance officers and other in-house counsel can take away from the late-November giving-shopping-doing spree (other than exhaustion!). With a bit of creativity, you can turn the sales and service holidays into compliance tips to carry forward into the new year. Taken in reverse order: Let’s think about reconstituting Giving … Continue Reading

Hard Data on the Cost of Noncompliance

A Corporate Compliance Insights article written by Peter Merkulov recently caught my eye because of its breakdown of the hard costs of compliance – and noncompliance. The title is “The True Cost of Compliance,” and the subject is the December 2017 report issued by Globalscape and Ponemon Institute called “The True Cost of Compliance with … Continue Reading

Rise Above ‘Why Compliance Programs Fail’ With Behavioral-Based Tips

I recently cracked open my Harvard Business Review to the article on “Why Compliance Programs Fail.” I read with great interest the authors’ theory on how weak, milque-toast metrics can result in check-the-box, paper-only compliance programs. I don’t disagree at all, but I have a few practical suggestions to add. The authors cite, as have … Continue Reading

In Light of the Brand Memo, Has the Way of Compliance Gone by the Wayside?

After then-U.S. Associate Attorney General Rachel Brand issued a memorandum (known as the “Brand Memo“) in January 2018, which some have interpreted as recanting all reliance on DOJ guidance documents, what’s next? Call me Pollyanna, but I contend that “the way of compliance” is here for good. Pun intended. First, annual survey results list compliance matters as … Continue Reading

Countdown to GDPR Deadline: What Your Organization Should Be Doing to Prepare

In late May, the European Union’s new General Data Protection Regulation (GDPR) takes effect, changing the manner in which companies all over the world – not just those in the EU – store and use Europeans’ personal data. GDPR requires any company that collects personal information of European citizens to comply with its data privacy … Continue Reading

The 12 Days of Compliance

Like a gift that keeps on giving, compliance efforts now can provide long-lasting benefits into the new year. I have written before about the guidance document from the U.S. Department of Justice that was issued in February of this year regarding compliance programs. More recently, in October, Deputy Attorney General Rod Rosenstein left no doubt … Continue Reading

Uber’s Troubles: A Compliance Wake-Up Call No Matter How Regulated You Are

I can’t help myself; when I read some of the troubling reports about Uber’s workplace culture, which has contributed to executive ousters and the need to hire one of the highest-profile lawyers in the country, I think, “If only they had a culture of compliance.” I wrote last month about “the way of compliance” positively … Continue Reading

The ‘Way of Compliance’ Adds Value Regardless of Who’s in the White House

I am astonished there are still so many articles out there advising readers on how to establish the imperative for compliance. Nearly 15 years after the rise of compliance to an officer-level position, with significant reporting obligations to a company’s audit committee and/or board, is it really true that the profession has to continually justify … Continue Reading
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