Certain customers, vendors, and intermediaries represent a higher compliance risk than others. Risk indicators include geography, relationships to government officials, business type, method of payment, and dollar volume. In places where risks are very low, compliance burdens can be reduced. Where risks are not low, compliance is heightened . When there are more red flags, … Read more »
Category: Compliance Programs
SEC Internet Enforcement
In the December Issue of Compliance Week, Bruce Carton tells some of the history of the SEC’s enforcement history. One of the first internet efforts was an email address for the public to send tips. Back in 1996 there were about 20 complaints a day. Now there as many as 10,000 a day. With all … Read more »
Lessons from Rome
Mary Bennett of the Ethical Leadership Group wrote three lessons we can learn from the ancient Roman army: First, there is the timeless importance of culture. People in a society or organization will behave according to the most widely accepted common denominator, modeled by those at the top. We must train and communicate with our … Read more »
GRC Predictions for 2009
Sumner Blount of CA has published his GRC Predictions for 2009. Risk will continue to grow in importance. Risk and compliance initiatives will continue to be consolidated. A shift in how risk is perceived and categorized. Continued regulatory requirements. Read more »
SEC Inspector General Testifies In Congress
SEC Inspector General H. David Kotz In the first Congressional hearing since the Madoff scandal broke in December, Mr. Kotz said his agency’s handling of the Madoff case may be a symptom of more widespread problems with how the agency handles its examinations and investigations. Kotz testified on the subject of “Assessing the Madoff Ponzi … Read more »
You Need An Impartial Chief Compliance Officer
As Merritt Maxim of CA points out, Madoff Scheme Highlights Need for Impartial CCO, one of the biggest red flags in the Madoff scandal was that was the disclosure that Madoff’s brother Peter served as the firm’s Chief Compliance Officer. “While having any sibling or family member serve as a CCO should not be an … Read more »
Corporate In-House Counsel in the Age of Internal Compliance
You can listen to a webinar from the Georgetown Journal of Legal Ethics Fall Symposium – Corporate Compliance: The Role of Company Counsel from October, 2007. Panel III – Corporate In-House Counsel in the Age of Internal Compliance Mitt Regan, Professor, Georgetown Law Tanina Rostain, Professor of Law, New York Law School Kathleen Barlow, Vice … Read more »
The Roles and Responsibilities of the General Counsel in the Organization’s Ethical Culture
The Markkula Center for Applied Ethics at Santa Clara University hosted a panel discussion on The Roles and Responsibilities of the General Counsel in the Organization’s Ethical Culture. The panel consisted of: Tom McCoy, executive vice president, legal affairs, and chief administrative officer, Advanced Micro Devices, moderator Craig Nordlund, senior vice president, general counsel and … Read more »
What Is Your Scope of Compliance?
Unified Compliance Framework put together this list of compliance requirement and regulatory schemes that may need to be part of your compliance program. Below is a long list of regulatory schemes that may need to be part of your compliance framework: Sarbanes Oxley Guidance Sarbanes-Oxley Act (SOX) PCAOB Auditing Standard No. 2 AICPA SAS 94 … Read more »
Compliance Boundaries
One way to view compliance policies is grouping them into mandatory and voluntary policies. Mandatory are those dictated by law. Voluntary are those the organization has imposed to futher business objectives and manage risk. Thanks to Carole Switzer, President of OCEG for this perspective. Read more »