Richard Bistrong: At Compliance Week 2016, Compliance 2.0 takes center stage

Richard Bistrong – The FCPA Blog – May 31, 2016

When prosecutors, regulators, and compliance practitioners agree on anything, I pay special attention.

Last week,  Compliance Week 2016 opened with a panel of Stephen Cohen, Associate Director of the SEC Division of Enforcement and Andrew Weissmann, Chief of Fraud Section of the DOJ Criminal Division. Their topic: “Are We Defining Effectiveness Correctly?”

Cohen and Weissmann were clear about the importance of the independence of the compliance function. The issue of reporting relationships, from their perspective, wasn’t as significant as the weight of compliance being able to voice disagreement, deal with conflict, and integrating into the business.

. . .

Read this article on The FCPA Blog.

Hui Chen, Walmart and the Radical Transformation of Compliance?

Mike Scher – The FCPA Blog – May 27, 2016

In my last post I discovered the power of images to make a point, like the ribbons of marble floating on air. The Blue Marble, NASA”s image of earth from space, changed how we see the planet, our home.

The radical transformation of compliance in the last four years is hard to grasp. There is astonishing momentum since the Walmart story broke in 2012. However, the upcoming DOJ settlement with Walmart (if there is one) will test that momentum. With a dubious DOJ leak and successful delays in the courts, is this the end of the transformation?

. . .

Read this article at The FCPA Blog.

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

Thomas Fox – FCPA Compliance Report – May 26, 2016

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal department into the compliance department or worse, some lawyer who is just given the title of CCO and this is considered to be a best practice or even sufficient. In the opening keynote presentation, representatives from the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made clear they expect a CCO to know more than simply the laws of anti-corruption, they must actually work to do compliance in an organization. A key metric of doing compliance is the independence of the CCO and compliance function.

. . .

Read this article on the FCPA Compliance Report.