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: empowerment, independence, a seat at the table, line-of-sight, resources, and, of course, true Compliance SME — the important foundational element of a successful compliance function.
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 Board, the Oversight Committee; and at the business unit level and the Baker Hughes Inc. (BHI) GeoMarket Compliance Committee. Today I want to change this focus from the committee concept and structure to a role on the Compliance Committee at the Board of Directors level.
Every Board of Directors need a true compliance expert sitting on their Board. Almost every Board has a former Chief Financial Officer (CFO), former head of Internal Audit or persons with a similar background and often times these are also the Audit Committee members of the Board. Such a background brings a level of sophistication, training and subject matter expertise that can help all companies with their financial reporting and other finance based issues. So why is there not such subject matter expertise at the Board level from the compliance profession?
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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?
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