From James Glanz and Riyadh Mohammed of the New York Times: Premier of Iraq Is Quietly Firing Fraud Monitors. The dismissals, which were confirmed by senior Iraqi and American government officials on Sunday and Monday, have come as estimates of official Iraqi corruption have soared. One Iraqi former chief investigator recently testified before Congress that … Read more »
Category: Compliance Programs
Assessing Corporate Culture
Ed Petry of the Ethical Leadership Group put together a two part paper on Assessing Corporate Culture: Assessing Corporate Culture – Part I and Assessing Corporate Culture – Part II. [There are] specific steps that compliance and ethics officers can take to begin the process of identifying their organizations’ culture including: • Conduct surveys, focus … Read more »
UK’s Law Commission on Reforming Bribery
The United Kingdom’s Law Commission has published its recommendations in a new report on reforming the bribery laws in the United Kingdom. The LC Report 313 on reforming bribery (.pdf) states: Bribery has been contrary to the law at least since Magna Carta declared, “We will sell to no man…either justice or right”. Most people … Read more »
Top Ten Ways to Prevent Employee Theft
From Tracy Coenen of the Fraud Files Blog, Top Ten Ways to Prevent Employee Theft: 1. Education . If employees are aware of fraud and how it happens, they will be your best on-the-job sleuths. 2. Surprise Audits . . . 3. Hotlines . A mechanism for anonymous reporting of fraud encourages employees to look … Read more »
Fraud Detected More Often At Bankrupt Companies
Bankrupt companies are three times more likely to have been cited for fraud by U.S. regulators, according to a study released on Monday from Deloitte Financial Advisory Services LLP. The study also showed that fraud incidents were much more likely to land a company in bankruptcy court. Sheila Smith, head of reorganization services at Deloitte … Read more »
Leading Corporate Integrity: Defining the Role of the Chief Ethics and Compliance Officer
Fellows of the Ethics Resource Center, Business Roundtable Institute for Corporate Ethics, the Ethics and Compliance Officer Association, the Open Compliance and Ethics Group (OCEG), and the Society of Corporate Compliance & Ethics put together Leading Corporate Integrity: Defining the Role of the Chief Ethics and Compliance Officer (pdf). Senior corporate executives are under great … Read more »
Opening Securities and Futures Accounts from an OFAC Perspective
The Office of Foreign Assets Control published new guidance specific to the securities industry on 11/06/2008: Opening Securities and Futures Accounts from an OFAC Perspective. A strong OFAC compliance program consists of procedures that are similar to those found in a brokerage firm’s Customer Identification Program (“CIP”). Firms should use risk-based measures for verifying the … Read more »
Corporate Governance of Public Web Sites
Jane K. Storero and Yelena Barychev of The Legal Intelligencer and Law.com authored an article that the system of reviewing and monitoring information posted on a company Web site should be part of the disclosure controls included in the enterprise-wide risk management system established by the company: Corporate Governance of Public Web Sites. This article … Read more »
The Implications of Stone v. Ritter
In 1996, Delaware’s Court of Chancery stated in the Caremark case that a director’s duty of good faith includes a duty to attempt to assure that a corporate information and reporting system exists, and that failure to do so may, under some circumstances, render a director liable for losses caused by the illegal conduct of … Read more »
Corporate Compliance And Ethics Week
The Society of Corporate Compliance & Ethics is promoting the week of May 3-9, 2009 as Corporate Compliance & Ethics Week. Read more »