Entries by Administrator

New DOJ Guidance – Evaluation of Corporate Compliance Programs

Released earlier this month with little fanfare, the Department of Justice Criminal Division Fraud Section released guidance on how to evaluate the effectiveness of a corporate compliance program.  The document has Compliance Counsel Hui Chen’s fingerprints all over it, as the DOJ has again expressly endorsed the key attributes of the modern Compliance 2.0 model: […]

J.P. Morgan Shuffles Top Compliance Posts

Emily Glazer – The Wall Street Journal – February 2, 2017 The Wall Street Journal discusses the shuffling at the chief compliance officer position within J.P. Morgan.  Of note, the “Journal reported last year that regulators are focusing more on who compliance executives report to give them more independence from executives who set policies and manage […]

Compliance Expertise Needed on the Board

Thomas Fox – JD Supra – December 22, 2016 This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of Director’s level; at the junction between the Chief Compliance Officer (CCO) and […]

American Subsidiary Reflects Japan Parent’s Sense of Ethics

Ben DiPietro – WSJ Risk & Compliance Journal – August 31, 2016 Kasey Ingram, general counsel and chief compliance officer for biosciences and chemicals company ISK Americas, a subsidiary of Japan-based Ishihara Sangyo Kaisha Ltd., discusses how Japanese culture helps drive compliance at the company and why the company maintains its compliance function within its legal department. The […]

Are compliance officers at financial institutions now in the hot seat for fines?

Stanley Foodman – The Yucatan Times – August 16, 2016 Otherwise reputable financial institutions continue being sanctioned for regulatory non-compliance.  Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering (AML) procedures.  The Financial Industry Regulatory Authority (FINRA) recently fined Raymond James & Associates and Raymond James Financial Services […]

A Trip to the Dentist for Some Compliance Insight

Thomas Fox – JD Supra – August 10, 2016 I had to go to the dentist yesterday. I went for what I thought was filling repair but I had somehow forgotten that it was a wisdom tooth removal and a filling repair. I know you are thinking either (1) why does someone his age still […]

Compliance front and center

Thomas Fox – Compliance Week – June 21, 2016 The past couple of months has confirmed a trend we have seen for some time in the world of Foreign Corrupt Practices Act and greater anti-corruption compliance. It is the continued growth in the importance of doing compliance in the eyes of the Justice Department and […]