Let’s talk about shareholder activism. After all, activism has reached dizzying heights this summer and it’s likely to stay there for a long while. That will eventually affect all operations of a business, including its regulatory compliance and audit programs. Oh, you thought I meant those Occupy Wall Street protesters? No. Those protesters are people; […]
Matt Kelly
Congress Missing the Point, Yet Again
Another week, another foolish attempt from Washington to impose a simple solution to our economy’s complex problems. And as usual, the Sarbanes-Oxley Act is right in the middle of things. Witness legislation from a gaggle of Republican Congressmen that seeks to exempt far more companies from Section 404(b) of the Sarbanes-Oxley Act. Their bill would […]
Imposing a Duty to Report, Part II
In last week’s column I posed the question of whether a company can require employees to report misconduct when they see it. My contention was—and still is—that compliance officers are in a predicament: impose a duty to report misconduct, and you could expose your company to retaliation complaints if someone ignores you; don’t impose one, […]
Frustrations Rise on Whistleblower Hotlines
So there we were, about 70 of us, sitting in rows last week in a conference room at the Cosmopolitan Hotel in Las Vegas. We had come to attend the Society of Corporate Compliance & Ethics’ annual conference, and at that exact moment were listening to a superb analysis of whistleblower hotlines by Stephen Epstein, […]
Managing the Contagion of Risk
My Saturday afternoon started with a rather mundane experience I’m sure many of you have done yourselves: I called a friend on my cell phone while I was walking to the store. She answered, and we chatted while she watched her daughter play at the park. Sounds ho-hum, right? But when you break down that […]
The PCAOB’s Big Debate
Now that we’re all settling back into the office, the compliance community has any number of serious issues looming in front of us this month. To my thinking, however, few have as much potential to change the compliance function’s day-to-day workings as the Public Company Accounting Oversight Board’s ambitions to reshape how the auditing industry […]
The Risks of Poor Risk Management
Two ill winds blew through Washington last week. Both left me uneasy about the precarious state of risk assessment and management in this country, which has already been buffeted so much by recession and disruption. Let me start with the less dangerous of the two: Hurricane Irene. Irene has left me stranded in Sacramento, Calif., […]
The Future of Articles on Internal Audit
In hindsight, I suppose we should have anticipated that an article about the career skills and needs of internal auditors would get heightened scrutiny. That is, after all, what internal auditors do: pay close attention to statements others make. Nevertheless, Compliance Week boldly ventured forth last week with an article on that subject, “Studies Find […]


