When a compliance officer needs to vote with his feet, the key ingredients to look for at the next job are, among other things, a chief compliance officer who reports to an independent board, and incentives or bonus pay for outstanding work. … Continue Reading
Myanmar’s opposition leader Aung San Suu Kyi spent the past four days in Singapore, meeting leaders, visiting schools, and putting some distance between herself and the city-state’s model of economic success.… Continue Reading
When I first read the headline last summer, I thought the article was written by “The Onion.” Titled Marion Barry lectures on ethics during chaotic Council session, it described a mind-blowing D.C.… Continue Reading
Editor’s note: This is the third post in a series dealing with the duties of compliance officers. The first post is here and the second is here.
Dear Compliance Officer
First, let me confirm your sense of reality.… Continue Reading
A compliance professional working in China posed this question: What is the role of a compliance professional?
I answered the question in my post, The Job of a Compliance Officer is to Tell the Truth.… Continue Reading
Yesterday, in Part I of my series on Virginia’s ethics laws, I discussed the corruption scandal threatening to end Governor Bob McDonnell’s political career. While the list of gifts and payments he has accepted from Jonnie R.… Continue Reading
A new Russian law, which went into effect on January 1, 2013, affirmatively requires companies to establish compliance programs.
The law, which was added as Article 13.3 of a broader 2008 Law on Combatting Corruption, is entitled “The Requirement of Organizations to Take Measures to Prevent Corruption” and provides that organizations are required to develop and implement measures to prevent corruption and states that such measures may include the following:
… Continue Reading
(1) designating departments and officers responsible for preventing bribery and related offenses;
(2) developing mechanisms for cooperation with law enforcement authorities;
(3) developing and implementing standards and procedures designed to ensure ethical business conduct;
(4) adopting a code of ethics and professional conduct for all employees;
(5) establishing means for identifying, preventing and resolving conflicts of interest; (6) preventing the creation and use of false and altered documents.
In the new DOJ-SEC Guidance there is a hole big enough for a Wal-Mart truck to drive through.
The Guidance (pp. 17, 26, 52-65) has many hypotheticals to illustrate “Guiding Principles of Enforcements,” “Hallmarks of Effective Compliance Programs” and what violates the FCPA or securities laws.… Continue Reading