I’m often asked for my thoughts about the future of compliance. What people really want to know is, what’s the next level of compliance? How do we improve? For me, the answer is corporate consciousness.… Continue Reading
What standards should businesses observe in their own countries, or abroad? Businesses now have resources and influence that rival or surpass those of governments and certainly of ordinary people. Yet finding globally appropriate rules for business behavior has been a formidable challenge for business leaders and academics.… Continue Reading
A friend of the court (amicus) brief explaining the fundamentals of compliance programs should be prepared, possibly by a new working group led by former DOJ and SEC officials, facilitated by the Rand Center for Corporate Ethics and Governance.… Continue Reading
It’s astonishingly good news that after forty years of trial and error to develop the compliance profession, the law finally evolved to require both a new business “culture” and the compliance officer position to make this “culture” happen. … Continue Reading
In the holiday spirit, here’s a last glance back at 2013 and a look at how the compliance profession is doing.
When I started legal practice over 30 years ago, there were no anti-corruption compliance departments and no “ethical business culture” issues.… Continue Reading
Malaysia’s Department of Islamic Development (Jakim) said in a sermon Friday that Muslims should combat the scourge of corruption because it can ruin a nation and civilization.
To balance the excitement over recent reports of the DOJ’s tough investigation and a new CEO at Wal-Mart, we could consider what compliance officers are taught by the SCCE: Lawful but awful does not mean everything is OK; it’s a wake up call and a test of the company’s identity.… Continue Reading
The recent announcement that the U.K.’s legislature and enforcement agencies are considering the case for financially incentivizing whistleblowers in economic crime cases, thus aping the U.S.-approach, presents a serious and insidious threat for U.K.… Continue Reading
The SEC’s associate director of enforcement, Stephen L. Cohen, left, had some great things to say when he spoke this week at the SCCE Annual Conference in Washington D.C.
Here’s part of what he said:
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I am surprised how infrequently companies try to persuade us at the front end of an investigation that they have a robust compliance culture and record of ethical conduct.… Continue Reading
If you’re a non-American compliance officer working in the hazardous, lawless conditions of many countries, it’s not clear what can be done. But this much is certain — COs working to create a code in China or India and so many other places need to know they have global support from compliance officers everywhere.… Continue Reading
Michael Scher’s post, The real code of conduct nobody mentions, brought this to mind.
In 1988 Robert Jackel wrote Moral Mazes, a ground-breaking book of corporate culture. Herein he addresses the fundamental rules of organizational life:
… Continue Reading