Menu3/15/16: In the March 2015 issue of Compliance and Ethics Professional (the publication of the Society of Corporate Compliance and Ethics), an article by Jeffrey M. Kaplan argues that not all corporate compliance programs “… are up to legal ‘snuff’ when it comes to risk assessment.” How can that be? Risk assessments are part of virtually all compliance programs. The problem is that many companies do not use their risk assessments in ways that comply with the Federal Sentencing Guidelines for Organizations’ requirement that they “design, implement, or modify each requirement…” of an effective compliance program to reduce risks identified through the assessment. Kaplan’s short article highlights ways in which some companies fall short and what they can do about it.
Compliance Communications Blog
3/15/16: Remarks prepared for Assistant Attorney General Leslie R. Caldwell's speech at the American Bar Association’s 30th Annual National Institute on white collar crime illustrate recent actions by the US DOJ in its ongoing push against corporate fraud. Global coordination and cooperation play the central roles in the investigation and prosecution of corporate fraud. As well as providing a review of recent activities, the remarks provide good insight into what the DOJ and its international partners see as priorities and opportunities to work together.
3/2/16: Some things happen just once a year – and that’s quite enough, thank you – including the annual April 15 tax deadline. Other things, like compliance training, can’t be limited to a once-a-year event if they are to be effective. Joel A. Rogers’ recent post on the Communicate Compliance Blog aims directly at the too-typical annual compliance training paradigm and addresses the question of why it isn’t enough with three key reasons. Understanding why once-a-year learning isn’t enough is the starting point to building a program that does achieve its goals of better compliance and ethical behavior.
