Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
[…] fired another senior executive — one mentioned as a possible CEO candidate — for personal misconduct. Earlier in the year, the company terminated its head of global human resources on the same grounds. Most significantly, its leadership articulated the departures and publicly linked them to BlackRock’s culture. “Our culture has always been one of […]
[…] with data protection expertise. Use predictive coding software to avoid sharing personal data inadvertently — comfort can be obtained by the use of machine learning rather than human review to exclude personal data. Brexit in the UK and the current inclination to relax privacy protections in the United States in the name of national […]
[…] “damned things.” Maybe the last line of defense isn’t only a written plan, but also something much deeper. Maybe compliance, finally, owes more than we think to human relationships. If the sales and marketing folks like and respect their compliance officer, can that change what happens, as much as any plan? 5. Perception is […]
[…] integral part of the justice and regulatory systems. It is imperative that all countries adopt a whistleblowing policy, for reward or otherwise, that protects what is a Human Intelligence Source. As Haile Selassie once said: “Throughout history, it has been the inaction of those who could have acted; the indifference of those who should […]
[…] SEC said. The bank had an FCPA compliance policy “but maintained few specific controls around the hiring of customers and relatives of customers, including foreign government officials.” Human resources personnel were not trained to flag potentially problematic hires, the SEC said. According to the SEC’s order, “Senior managers were able to approve hires requested […]
[…] relative strengths and weaknesses in compliance programs, but without a “pass-fail” result. 5. Clarify scope of reviews. Clarify that reviews look at three levels of analysis: The design of the program, its implementation and its impact/effectiveness. 6. Deeper reviews. Make clear that in reviews there must be transaction testing, field reviews, and interviews with […]
[…] They Do it: Inside the Mind of the White Collar Criminal, by Harvard Business School Associate Professor Eugene Soltes. In his riveting work, Professor Soltes says “the human ability to sense the potential for harm is significantly affected by physical and psychological proximity.” Professor Soltes had reached out to incarcerated executives to ask: What […]
[…] Compliance will lead the execution, reporting and evaluation of our global training and communications programs for our international markets. The Director will also be responsible for the design and delivery of anti-corruption training for executives. This role will travel approximately 25-30% including both domestic and international travel. Key Responsibilities: • Provides strategic direction […]
[…] respect for those who serve the public, including the prosecutors at the DOJ. Without them, the ‘rule of law’ would just be pretty words. But everyone is human and stuff happens. So today we’re looking at the DOJ’s worst five FCPA enforcement actions of all time. Some defendants on the list faced stacked charges. […]
[…] career at a local agency. I made a mistake too, and I learned a lot more than how not to use a knife through it. It is human nature to see the shortcomings of those we are training in the worst light possible while whitewashing our own missteps as the unfortunate result of good […]
