Building a compliance program from the ground up from a well-conceived blueprint is a luxury few compliance professionals enjoy. Most companies already have some initiatives in place—an environmental, health, and safety program or anti-money laundering policies, for example. While the existence of such programs is not necessarily bad in itself, building on to them can […]
Karen Kroll
Posted inAnti-Bribery
Elements of Effective Compliance
There’s no shortage of guidance from regulators around the world on what a good compliance program should entail. In theory, documents such as the U.S. Federal Sentencing Guidelines and many others should help compliance departments design robust, sensible programs. In practice, however, the proliferation of such guidance can make the job daunting and confusing. The […]
Posted inEthics & Culture
Hotline Benchmarking Report Reveals Insight Into Compliance
The 2012 Corporate Governance and Compliance Hotline Report has some alarming findings for compliance officers: fraud and instances of retaliation against those who report it are on the increase. According to the report, the percentage of incidents related to fraud continues to grow, hitting 21.1 percent of all reports, up from 13.6 percent in 2007. […]
Posted inAccounting & Auditing
Integrating Risk Appetite and Risk Management
JPMorgan Chase’s recent admission that a trader in London lost $2 billion trading in credit derivatives is yet another reminder of the importance of spelling out a company’s risk appetite and integrating it with risk-management practices. Three years after the financial crisis, it’s clear that companies are still struggling with how to manage risk in […]
Posted inRegulatory Enforcement
What’s the Holdup With Dodd-Frank Rulemaking?
Even though the “Volcker rule” is scheduled to go into effect this July, many banks aren’t sure exactly how they’ll comply with it. That’s because a final version of the rule still doesn’t exist. While the Securities and Exchange Commission, the Federal Reserve, and other federal agencies proposed a version of the Volcker rule in […]
Posted inFrom the Archive
How Compliance Officers Conquer Stress
Few question whether the compliance officer job is stressful. Finding ways to cope can make the difference between just treading water and running an effective compliance function. And the pressure is only getting worse. The volume of regulations continues to expand, as well as the responsibilities that many compliance officers are expected to handle. In […]
Posted inFrom the Archive
Measuring the Effectiveness of Compliance
The conventional wisdom is that what gets measured gets managed. But apply that wisdom to the question of measuring effectiveness of an ethics and compliance program, and things start to get a bit fuzzy. Perhaps that’s why in the 2011 State of Compliance report published by Compliance Week and PwC last year, a full 38 […]
Posted inBoards & Shareholders
SEC Speaks on Proxy Access
The Securities and Exchange Commission has fired off another round of decisions about no-action letters companies have submitted looking to keep shareholder proposals off the proxy statement—including a few proposals about shareholder access to the proxy statement overall. Corporate governance experts are paying close attention to the SEC’s response to no-action requests this year because […]
Posted inInternal Controls
Starting a Compliance Program From Scratch
As many compliance officers know, being a compliance department of one, even with some administrative support, is difficult enough. What if you’re an organization’s first-ever compliance officer? How do you go about building a program from scratch? The initial and most important step is ensuring that the program is correctly positioned, says Donna Boehme, principal […]
Posted inData Privacy
SEC Turns Up the Heat on Private Equity, Hedge Funds
During the past few months, the private-equity and hedge fund industries have been getting the white-glove test from the Securities and Exchange Commission, and the SEC is turning up plenty of dirt. In December, the Commission announced charges against a half-dozen hedge fund managers or partners for improper use of fund assets, fraudulent valuations, and […]
