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The SEC’s New Aggressive Tack 27 Aug 2013 | 08:20 am
As a former US Attorney for the Southern District of New York, Mary Jo White promised a new and more aggressive SEC. She is starting to deliver on that promise. Reams and reams of client alerts have...
The Chief Compliance Officer as a Corporate Leader 26 Aug 2013 | 02:37 am
Companies are embracing the independent and empowered chief compliance officer. The trend is continuing to grow and there is no reason it will stop. CCOs are no longer reporting to the general couns...
Vendor/Supplier Due Diligence: Tricky Issues and Twists and Turns 23 Aug 2013 | 07:34 am
You have to admire chief compliance officers for their tenacity and ability to multi-task. They are the consummate jugglers of important projects, strategies and tasks. They can never completely fin...
Dancing Around the Edges: Renewed Focus on Gifts and Hospitality 22 Aug 2013 | 07:46 am
A confident person is willing to admit a mistake. An insecure person is unwilling to admit a mistake, even in the face of overwhelming evidence contrary to his or her argument. Not that my prior pos...
The Risks of a Defective Internal Investigation 21 Aug 2013 | 06:04 am
Lawyers and compliance professionals repeatedly tout the importance of an internal investigation to protecting a company from devastating consequences from an enforcement action. An internal investig...
All in the Family: Enforcement Focus on Hiring of Relatives of Foreign Officials 20 Aug 2013 | 04:47 am
Can you imagine being the public relations director for China these days? Even in the limited world of foreign bribery, the Chinese have had a rough couple of weeks. Add the latest news to the mix a...
Reactive Compliance: An Oxymoron? 19 Aug 2013 | 05:24 am
People make bad decisions. Companies make bad decisions. In fairness, sometimes a bad decision is the result of a failure to act, or a failure to prioritize. We are surrounded by oxymorons in our w...
The Rise of Compliance Professionals 16 Aug 2013 | 06:19 am
The hottest commodity on the job market is the compliance officer. It is about time. No longer are compliance officers considered second-rate professionals, relegated to back office positions and au...
China and Compliance Solutions: Choking Off the Money Supply 15 Aug 2013 | 08:25 am
Compliance is hard enough even when the issues are simplified, the tasks are defined, and the strategies are straightforward. It is all too easy to complicate an issue, wrap it in legalese, and techn...
Making Your Training Program Effective 14 Aug 2013 | 05:02 am
Returning to the theme of profound grasps of the obvious, compliance officers face numerous challenges where they need creativity and persistence. One area which is not as hard as others is training....
