Apparently the Securities and Exchange Commission achieved so much acclaim last year when it published its Financial Reporting Manual last year that the agency is doing it all over again. Speaking yesterday at Financial Executives International’s annual financial reporting conference, the top accountant at the SEC’s Division of Corporation Finance, Wayne Carnall, said he and […]
Matt Kelly
The Myth of the Black Swan
Perhaps it’s time to start shooting those black swans. For the last several months we’ve all heard more and more about risk management, primarily because a class of supposed geniuses on Wall Street ruined the economy for the rest of us. Now the buzzword in Washington is risk management, all the time. And the most […]
Editorial: Anatomy of an FCPA Violation
So I may have violated the Foreign Corrupt Practices Act while I was on vacation recently. Now, for the several readers of these pages who work at the Justice Department, let me state clearly that I’m not sure I violated the FCPA, and this isn’t an episode of self-disclosure. But while on vacation in South […]
Shooting the Breeze About Internal Auditing
Yesterday I had the pleasure of hosting another of Compliance Week’s occasional editorial roundtables, where we gather a small group of compliance or governance executives to discuss issues of the day in corporate compliance. We hosted a dozen internal audit executives in New York, to talk about internal auditing’s transformation these days into a much […]
Why Workers Violate the FCPA: My Story
So I may have violated the Foreign Corrupt Practices Act while I was on vacation recently. Now, for the several readers of these pages who work at the Justice Department, let me state clearly that I’m not sure I violated the FCPA, and this isn’t an episode of self-disclosure. But while on vacation in South […]
Editorial: CW Hosts First Virtual Governance Conference
I am big a fan of the printed page and the in-person gathering. This month, however, we’re going virtual. Compliance Week will host its first “virtual” conference on Oct. 28-29, entirely online at http://econference.complianceweek.com. It’s free and open to all, and once I describe what we’re trying to accomplish, I’m sure you’ll find it as […]
Compliance Tips From People Who Know
Any compliance officers looking for ammunition to take into budget planning meetings for 2010, I have some for you—not that the news is exactly what corporations want to hear. I’ve been attending the Society for Corporate Compliance and Ethics’ annual conference for the last two days, and this morning attendees heard an excellent presentation from […]
Editorial: How’s Your Global Integrity These Days?
By now you’ve probably noticed something strange about this month’s magazine: It arrived in an unusually large package, with an unusually large supplement tucked into the wrapping: our 2009 Global Integrity Survey. Normally I reserve this space to discuss articles and information inside the magazine, but the survey deserves special attention from both me and […]
The Wrong Action for the Right Reasons?
I’ve been writing about corporate compliance for a long time, and like most executives who use Compliance Week, I’ve become comfortable using the abstract terms we all do when talking about the idea of “compliance.” But two incidents in the news recently remind me that for all our theoretical understanding of how compliance should work, […]
Editorial: No Fairy Tale Ending for Economic Woes
Once upon a time, the United States had a crisis. Our financial system collapsed; our investment funds were exposed as Ponzi schemes; stock prices cratered; and unemployment soared. Times were grim. So the United States did what it always does in crisis, when all other hopes have failed and no other choice remains: It put […]


