Archives: Compliance

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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

Board Engagement: The Ethics and Compliance Missing Link

It’s been a year since I wrote about The Board’s Overlooked Role in Compliance. At the time, it seemed that momentum was building for more proactive board engagement in establishing and overseeing compliance programs. After all, regulators and courts have been increasingly outspoken about the importance of effective compliance programs and pointed about the essential … Continue Reading

U.S. Government Continues Raising the Cost of Noncompliance

The U.S. Justice Department, the Federal Trade Commission, and other federal agencies recently announced their 2018 increases for civil penalties. As the costs of violations continue rising, it is imperative that companies develop a strong compliance framework to prevent compliance failures. The increases are a required part of the redundantly titled “Federal Civil Penalties Inflation … 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

Five Common Compliance Myths

The recently released Society of Corporate Compliance and Ethics 2017 Compliance and Ethics Officer and Staff Salary Survey contains a host of interesting CCO and other compliance personnel compensation information. Also interesting is the survey’s profile data regarding compliance professionals and their companies. The SCCE is a nonprofit association of more than 5,800 members, including … Continue Reading

The U.S. Justice Department’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised corporate enforcement policy for the Foreign Corrupt Practices Act. The revised policy is based on an FCPA pilot program (in place since April 2016), which provided mitigation credit for voluntary reporting of wrongdoing and specified levels of cooperation and remediation in connection … 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
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