One part of compliance is investigation. Find the facts. Don’t rely on opinion or self-interest statements. With all the hullabaloo about the Ground Zero Mosque I thought I would gather some factual information. First off. It’s not at Ground Zero. Just How Far Is the “Ground Zero Mosque” From Ground Zero? by Matt Sledge in … Read more »
Category: Compliance Bricks and Mortar
Compliance Bits and Pieces for August 6
Here are some recent stories that I found interesting: The FCPA’s Long Tentacles by FCPA Professor One reason is that mere existence of an FCPA inquiry can significantly throw a wrench into a company’s ability to sell itself. Another reason is that mere existence of an FCPA inquiry can cause an analyst to downgrade a … Read more »
Compliance Bits & Pieces for July 30
Here are some recent stories that I found interesting: When Compliance and Legal Functions Collide by Matt Kelly in Compliance Week‘s Big Picture The general counsel is still the boss. Yes, I know, the revised U.S. Sentencing Guidelines say companies should have an independent compliance function, with a chief compliance officer who answers to the … Read more »
My Encounter with a Black Swan
I had my first encounter with a black swan. Not Taleb’s Black Swan. A real black swan. From 2010 Blank Park Zoo in Des Moines Iowa The encounter was unexpected, but there was no significant loss or gain. Read more »
Compliance Bits & Pieces for July 23
Here are some recent stories that I found interesting: Dodd-Frank Forum: What would Brandeis think? by Mike Guttentag in The Conglomerate Louis Brandeis famously coined the metaphor (“sunlight is the best policeman”) that provided the philosophy underpinning the first federal securities acts (disclosure, disclosure, and more disclosure). I thought it might be fun to run … Read more »
Compliance Bits & Pieces for July 16
Here are some recent stories that I found interesting: Canada and the Corruption of Foreign Officials Act by Tom Fox The CFPOA was passed in back in 1999. However, up until this year, there was only one enforcement action under the legislation involving a Canadian company and no prior enforcement actions against individuals. The Canadian … Read more »
Compliance Bits & Pieces for July 9
Here are some stories I found interesting: Compliance Lessons in Country Music by Frank Sheeder in The Healthcare Compliance Blog We all get our inspiration from different places. As you will see, country music can support some of the best themes that we can establish as compliance professionals. The titles of some of the more … Read more »
Compliance Bits and Pieces for June 18
Here are some recent stories that I found interesting: Who Does Your Chief Compliance Officer Report To? by Thomas Fox in a guest post on The FCPA Blog Should a CCO report to a company’s Board of Directors, or an appropriate Board committee such as an Audit Committee or Compliance Committee? Or can a CCO … Read more »
Compliance Bits and Pieces for June 11
Here are some interesting stories from the past week: SEC Union: Staff Need Not Check BlackBerrys After Hours by Bruce Carton in Compliance Week‘s Enforcement Action In short, Khuzami and his senior colleagues can call, email and text SEC Enforcement staff all they want after hours–but can’t do much about it if staff members fail … Read more »
Compliance Bits and Pieces for June 4
Here are some recent stories that I found interesting: The Auditors And Financial Regulatory Reform: That Dog Don’t Hunt by Francine McKenna in re: The Auditors The firms are broken and their basic product is worthless. The auditors were completely impotent to warn investors of over-leverage and risky business models, to prevent erroneous and potentially … Read more »