For the past seven years, LRN has conducted its annual survey of Ethics and Compliance programs in search of benchmarking data, suggestions of leading practices, and trends. In 2012 LRN adopted the Program Effectiveness Index as a tool to determine the impact of compliance programs. The challenge with index is figuring out the difference between … Read more »
Meet the SEC Whistleblowers
Since the Securities and Exchange Commission set up its whistleblower program in 2011, 6500 people have stepped forward as “whistleblowers.” Maxwell Murphy of the Wall Street Journal made a Freedom of Information Act request to find out more. How successful has the program been and are the people filing really “whistleblowers”? Of those 6500, only … Read more »
How Do You Exit a Ponzi Scheme?
It looks like Bernie Madoff was $45 billion short of funds in his “investment strategy.” How was he ever going to get out of this? The original Ponzi schemer, Charles Ponzi, seems to think he could get out of his situation, at least according to Mitchell Zukoff, author of Ponzi’s Scheme: The True Story of … Read more »
Weekend Reading: Busted
What do you do when the whistleblower sitting in front of you is an unreliable drug addict? Maybe you see some nugget of truth in the story. Maybe you see some way to find reliable evidence that proves that nugget of truth. Wendy Ruderman and Barbara Laker, reporters at Philadelphia’s Daily News were confronted with … Read more »
Compliance Bricks and Mortar for July 25
These are some of the compliance-related stories that recently caught my attention. What an Employment Lawyer Can Learn From Minecraft (or Not) by Daniel Schwartz in the Connecticut Employment Law Blog Minecraft is teaching a whole generation of “kids” (and not so “kids”) about the value of teamwork in a corporate culture. Moreover, there is … Read more »
Money Market Fund Reform Makes My Head Hurt
One of the critical moments of the 2008 financial crisis was caused by Lehman Brothers and its effect on the Reserve Fund, a money market fund. The fund had a significant amount of short-term debt issued by Lehman. Enough that the fund had to ‘break the buck.’ Now even “cash” was not a safe place … Read more »
Compliance Failures and Performance Measure
Progress Rail is under criminal investigation for failures in its railcar and locomotive repairs operation. Investigators claim that it was charging owners of rail equipment for making unnecessary repairs and replacements. There is also an environmental claim because the investigation indicates that workers were dumping parts in the ocean to hide them from auditors. That … Read more »
Compliance and Dodd-Frank at Four
It’s been four years since the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law. President Obama sat down on July 21, 2010 to sign the behemoth of a bill that was the most dramatic change to financial industry in years. Besides the hundreds of pages of text in the law itself, … Read more »
Compliance Bricks and Mortar for July 18
Book de Tour by Greig Leach These are some of the compliance-related stories that recently caught my attention. Big Settlements Elevate Compliance Officers in WSJ.com’s Risk & Compliance Journal Recent white-collar settlements are case studies in how compliance officers are ignored, circumvented and sidelined. But that’s likely having the effect of giving these staffers more … Read more »
Jack Ryan: Shadow Recruit
Movies about compliance officers are few and far between. It may surprise you to find Chris Pine playing that role in Jack Ryan: Shadow Recruit. Jack Ryan is the protagonist in Tom Clancy’s cold war thrillers. I read most of his books back in the 1980s. They were so cold war based I wondered how … Read more »