Tom Fox

In an interesting turn of events, the Och-Ziff corruption case recently reared its head once again, following news that Michael Cohen—who once oversaw the company’s investments in Europe, the Middle East and Asia—is facing criminal charges of fraud and obstruction of justice, according to recently unsealed court documents.

When it comes to following the money and staying in accordance with Department of Justice regulations, global payroll is the most well-suited corporate discipline to provide first-level oversight and controls.

The more the Justice Department talks about CCO independence, coupled with resources being made available and authority concomitant with the CCO position, the more corporations will see it is in their best interest to provide the resources, authority, and gravitas to compliance positions within their organizations.

Before beginning any layoffs, it is essential that the compliance practitioner work with the legal department and HR function to make certain employment separation documents are in compliance with SEC rules.

If you perform an annual Desktop Risk Assessment with a full worldwide risk assessment every two years, you should be in a good position to keep abreast of compliance issues that may change and need more or greater risk management.

A power outage at Atlanta’s Hartsfield Airport is a reminder to us all that having backup systems in place is essential to good business.

In this day and age, it would be wise for chief compliance officers to keep on top of the news, especially when it regards corruption, says The Man From FCPA.