Blog Posts Tagged with "cco"
Five Essentials of a Chief Compliance Officer Position
December 05, 2012 Added by:Thomas Fox
The five essential features are based on the Department of Justice’s thinking on the issue in the form of the US Sentencing Guidelines, FCPA enforcement actions and evolving best practices. If your company is not following these it may well not be deemed to have a commitment to compliance...
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How Do You Change to a Culture of Compliance?
August 23, 2012 Added by:Thomas Fox
Unlike the insurance industry, which helps companies manage risks through financial instruments, risk management attempts to avoid or at least control risk. The next time you hear the mindless prattle of “but we’ve always done it that way”, get some ideas on how to change your company’s compliance culture...
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The Compliance Professional as a Trusted Advisor
July 18, 2012 Added by:Thomas Fox
Compliance is ar form of risk you can measure, evaluate and then manage. If the risk becomes too great, that may create an unacceptable level which your company will not tolerate. One of your key roles of a compliance practitioner is to reduce the level of risk which your company cannot or will not tolerate...
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How the DOJ Looks at Compliance Programs Part 2
May 31, 2012 Added by:Thomas Fox
The ABA Primer notes that an effective compliance program consists of documentation that an organization “exercise[s] due diligence to prevent and detect criminal conduct; and otherwise promote[s] an organizational culture that encourages ethical conduct and a commitment to compliance with the law”...
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How the DOJ Looks at Compliance Programs Part I
May 22, 2012 Added by:Thomas Fox
Although often discussed in Deferred Prosecution Agreements (DPAs) or Non-Prosecution Agreements (NPAs), most compliance practitioners are not familiar with one of the most important sources of Department of Justice (DOJ) policy regarding the prosecution of corporations...
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Turn Compliance Beliefs Into Action: Impact Tone at the Bottom
May 11, 2012 Added by:Thomas Fox
This method is a good way for a compliance practitioner to get at ‘tone at the bottom’. By engaging employees at the level suggested you can find out not only what the employees think about the compliance program but use their collective experience to help design a more effective program...
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Compliance: To Boldly Go Where the Board Needs to Go
April 29, 2012 Added by:Thomas Fox
I was thinking about Captain Kirk and his leadership of the Enterprise in the context of issues relating the Board of Directors responsibility in a company’s compliance program. Kirk did not have to deal with a BOD, but he did lead from the front, and that is what a CCO must do...
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Three Keys to the Role of a Chief Compliance Officer
April 11, 2012 Added by:Thomas Fox
There is an ongoing debate in the compliance world about whether a company can or should combine or separate the role of the CCO from that of the General Counsel. Before a company can answer this question, it must meet No. 6 of the DOJ's minimum best practices requirement...
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Barbara Tuchman and Compliance Programs
April 04, 2012 Added by:Thomas Fox
Compliance professionals are continually try to get the message out at corporations. Here is some wisdom that Tuchman advocated and how it might help the compliance professional convey the essence of doing business in compliance across a corporation...
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Don’t Shoot the Messenger, Fire the Chief Compliance Officer
January 19, 2012 Added by:Thomas Fox
In the post Sarbanes-Oxley world, the CCO is a linchpin in organizational efforts to comply with applicable law. When a company fires or asks them to resign, it is of significance for all involved in corporate governance and should not be done at the CEO alone...
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Boards of Directors and Compliance: Four Areas of Inquiry
January 02, 2012 Added by:Thomas Fox
Any best practices compliance program has several moving parts, a CCO to lead the compliance program, a Compliance Department to execute the strategy and an engaged Board of Directors who oversee and participate. We applaud Hutchens approach and commend it for use by a company’s BoD...
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