“ALL THE ARMIES OF THE WORLD ARE NOT SO POWERFUL AS AN IDEA WHOSE TIME HAS COME.” –Victor Hugo
The rise of Compliance as a new profession – separate and different than Legal – and the rise of the modern model of Compliance 2.0 – untethered from Legal – is just such an idea whose time has come. 10 years of dialog, analysis, and debate on the topic has drawn on the rich comment and thought leadership of many from the legal and compliance professions, who have added their experienced commentary to the issue, often in the course of observing the details of the latest compliance scandal and observing the flaws in the legal-driven approach to compliance (Compliance 1.0). Here we give tribute to those who have shared their ideas on the topic, contributing in significant ways to the conversation about the evolving new model of Compliance 2.0:
On résiste à l’invasion des armées; on ne résiste pas à l’invasion des idées.
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: […]
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 […]
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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 […]
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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 […]
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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 […]
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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 […]
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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 […]
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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. […]
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 […]
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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, […]
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