Compliance Communications Blog


Lessons from Failed Internal Controls

11/17/20: The failure of Goldman Sachs’ compliance program led to a head spinning $3.3 billion settlement with the US Department of Justice and Securities and Exchange Commission. Why did the company’s program fail so miserably and what, if anything, does their experience have to teach other companies?

A post by Asher Miller on The FCPA Blog offers five “… takeaways for compliance officers everywhere” from the Goldman Sachs case. The takeaways are practical, but the pleasure of the post is in statements like this one: “Like in poker, if you can’t spot the fool around the table, it’s probably you.”



When the Choice is Between Ethics and Compliance

11/17/20: An article by N. Craig Smith and Piergiorgio Pepe posted on the MIT Sloan Management Review poses the challenge, “Ethics or Compliance in a Crisis? Companies stepping up to assist during the COVID-19 pandemic face hard choices in a new risk environment.”

The article creates a scenario that is immediately compelling as the growing number of virus infections triggers a corresponding increase in the need for medical supplies, personnel and space. The authors offer recommendations for “for all companies wrestling with how to provide help to those affected by a crisis while keeping the business going and sustaining ethical standards.” It’s a thoughtful article, well worth reading, and not just for the time of a pandemic.



Increase Compliance Spending in 2021

11/16/20: Compliance departments aren’t always at the top of the list for additional funding but, according to an article by posted on the Security Boulevard website, author Jingcong Zhao gives six reasons why compliance spending should be increased in 2021.

Among the six reasons: heightened regulatory scrutiny, third-party risk and the need to develop and demonstrate strong cybersecurity measures. Zhao’s article is practical and provides numerous links to additional resources.



UK’s Modern Slavery Act Updates

11/17/20: While attention focuses on compliance challenges related to the global pandemic, other regulatory agencies continue with implementation of other laws and regulations. One of them is the UK’s Modern Slavery Act, originally adopted in 2015. Following reviews, the UK has proposed changes to the Act including which organizations will be required to comply.

An article by Rebecca Emery of the law firm Ogletree Deakins and posted on firm’s website explains the proposed changes to the Act. She also offers recommendations for compliance officers “… in light of the proposed tightening of reporting requirements and potential future sanctions.”



Employee Benefits: Compliance and COVID-19

11/2/20: The coronavirus has assaulted business leaders from every direction, not least in managing employee benefits despite changes in workplace formats. An excellent article published by the global risk management, employee resources and insurance consulting firm provides practical action items to help in making decisions that affect employees and their benefits.

Each action item ends with a question that encapsulates the discussion, from “How do employee furloughs or reductions in hours impact your employees’ benefits coverage?” to what compliance issues will be triggered if the organization curtails benefits.