After three decades in the field, I realized at the SCCE tenth annual conference that something new is taking shape. Let’s call it the second generation of compliance.
Compliance 1.0 was an off-shoot of in-house legal work done mostly by lawyers.… Continue Reading
I could not help thinking about the astonishing positive changes that have occurred as I watched the SCCE’s September 16 general session on the new laws protecting whistleblowers enforced by the SEC’s Office of the Whistleblower.… Continue Reading
A new survey of chief compliance officers found that 38 percent of those with overall program responsibility report directly to their company’s CEO, while just 18 percent report to the general counsel or chief legal officer.… Continue Reading
The Pulitzer-prize winning NY Times reporter David Barstow famously wrote in 2012 that Walmart was an “aggressive and creative corrupter, offering large payoffs to get what the law otherwise prohibited. It used bribes to subvert democratic governance — public votes, open debates, transparent procedures.… Continue Reading
No one can say they haven’t been warned by the SEC (and the authors of the latest Hughes Hubbard FCPA/Anti-Bribery Alert) not to interfere with compliance officers.
Here’s an excerpt from the Alert about the new effort to protect compliance officers:
Recent statements and actions by the SEC demonstrate that the enforcement agency has adopted a broad strategy of seeking to protect and strengthen the position of compliance officers.… Continue Reading