Compliance 2.0: DOJ Pushes the Compliance Agenda

Michael Volkov – Corruption, Crime & Compliance – April 24, 2016

The FCPA Paparazzi have a thick head and a stubborn chin. They just do not understand the significance of Compliance 2.0 to corporate governance and they blindly adhere to simplistic, yet unexplained, solutions to complex problems – kind of sounds like a presidential candidate we all know.

Without getting into politics, which I avoid here on this blog, DOJ’s recent FCPA guidance on voluntary, disclosure, cooperation and remediation sets out an ambitious push on ethics and compliance programs. Of course, the new remediation elements apply only to those situations where companies are seeking cooperation and disclosure benefits, along with implementation of a remediation plan.

The new compliance elements represent validation of the Compliance 2.0 model, which has been advanced by leading compliance strategists, such as Tom Fox (here), Donna Boehme (here), Roy Snell (here), and Joe Murphy (here). Unlike many in the FCPA Paparazzi, they have been pushing new and innovative compliance strategies for years that flow from the elevation of an independent compliance function in global companies.

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Read this article on Corruption, Crime & Compliance.

The Empowerment of the CCO: Old Ways Die Hard

Michael Volkov – Corruption, Crime & Compliance – April 6, 2015

“Why not go out on a limb? That’s where the fruit is.”  — Will Rogers

” Change is the law of life and those who look only to the past or present are certain to miss the future.”  — John F. Kennedy

The compliance profession continues to evolve and grow.  More lawyers and law students are seeking knowledge and training in the field of ethics and compliance.  There is a reason for that.

Donna Boehme, a leader in the ethics and compliance field recently wrote an important column on Compliance 2.0, and the death of Compliance 1.0. (Here and Here). Michael Scher, another compliance leader, has several important postings on this issue on the FCPA Blog (Here and Here).

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Read this article at Corruption, Crime & Compliance.