I find that ineffective and unenforced policies are rampant within organizations, and are a thorn in the side of compliance and policy managers. Mismanagement of policy has grown exponentially with the proliferation of documents, collaboration software, file shares, and Websites. Organizations end up with policies scattered on dozens of sites with no defined understanding of […]
Risk Management
COSO Release New Paper on Risk Assessment
COSO has produced a new “thought paper” on risk management, offering ideas on how companies can raise their game with respect their particular approach to enterprise risk management. With the help of Deloitte & Touche to author the paper, COSO provides some ideas for corporate leadership on risk assessment approaches and practices that it says […]
Managing Compliance Risks in the Supply Chain
Last week, China-based electronics manufacturer Foxconn, best known as the contract manufacturer of Apple iPhones, admitted that underage “interns” as young as 14 were found working at one its factories. Incidents and allegations of sweatshop-like conditions at Foxconn have caused constant embarrassment for Apple and other electronics companies. Apple is hardly alone in having concerns […]
Sharpening Third-Party Risk Mitigation
Never has third-party risk management been as high a priority as it is in today’s stringent anti-corruption enforcement environment. Yet, many companies still aren’t up to snuff when it comes to refining the processes used to mitigate third-party risks. They are in a “relative state of paralysis,” says Kenneth Kurtz, chief executive officer of Steele […]
Identifying Compliance Risks and Trends
Many companies are fairly indiscriminant when it comes to gathering data. The idea is that if it might be useful at some point, they keep it. The result is that companies can easily become overwhelmed in a sea of data and find analyzing it, and knowing what to do with all of it trying. Colin […]
Tyco in Hot Water Once Again After FCPA Settlement
Anyone searching for some broader context to understand how Tyco International lurched into yet another bribery scandal—the third major misconduct meltdown to hit Tyco or one of its spin-off companies since 2002—would do well to ponder one of the most famous lines from The Godfather. “Just when I thought I was out,” crime boss Michael […]
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 […]
Anti-Bribery Enforcement on the Rise
Tougher enforcement of anti-bribery laws around the world has resulted in more companies facing prosecutions, according to a new report from anti-corruption watchdog Transparency International. Countries involved in the Organization of Economic Cooperation and Development’s Anti-Bribery Convention, a coalition established to fight global corruption, added a total number of 144 open cases of criminal prosecutions, […]
Studies Confirm New Ideas on Risk Management
A pair of recent studies by accounting firms confirm an increasing number of companies are retooling their risk strategies as a result of recent economic turmoil and persistent uncertainty. More than half of the nearly 200 executives who participated in a joint study by Deloitte & Touche and Forbes Insight said they expect their organizations […]
AML Compliance Back in the Spotlight
Well, one explosive report about drug cartels and terrorist groups funneling money through U.S. banks, plus one compliance officer announcing his resignation during a U.S. Senate committee hearing, and presto—anti-money laundering efforts, and the lack thereof, are back in the news. The specific bank on the anvil of public discontent right now is HSBC, the […]


