Internal Controls


Telephone

When academic studies and hoax hotline claims go ‘off the rails’

2021-10-18T17:26:00+01:00By

Imagine this: An anonymous hotline tip comes through that a senior executive has engaged in insider trading. This scenario happened this summer as part of academic research, effectively leaving hundreds of unwitting corporate subjects to foot the bill for unnecessary follow-up conducted.

United States cyber

How to respond to government’s renewed emphasis on cybersecurity

2021-10-15T20:30:00+01:00By

The Department of Justice’s new Civil Cyber-Fraud Initiative is the latest development to suggest companies’ cybersecurity defenses had better be up to snuff when doing business with the U.S. government or risk enforcement.

SEChq

SEC’s Gurbir Grewal stumps for proactive compliance in first speech

2021-10-08T17:49:00+01:00By

In his first publicized speech as director of the Securities and Exchange Commission’s Division of Enforcement, Gurbir Grewal spoke to the importance of “modeling excellence” in compliance efforts.

ask cco 3x2 pendergrass

Ask a CCO: How do you get leadership to support compliance?

2021-10-08T13:00:00+01:00By Compliance Week

Seven senior compliance practitioners impart how to get leadership to understand the value compliance offers the business and commit to supporting ethical initiatives.

ask cco 3x2 schwager

Ask a CCO: How to ensure right things done for right reasons

2021-10-07T13:00:00+01:00By Compliance Week

How do you encourage employees to do the right things for the right reasons? Seven senior compliance practitioners share what they and their respective companies do to best get results.

Petrobras

Petrobras fulfills obligations of 3-year FCPA agreement

2021-10-06T16:41:00+01:00By

Brazilian state-owned energy company Petrobras announced it has met the obligations of a three-year agreement reached with the Department of Justice for playing a role in one of the world’s largest political corruption investigations.

ask cco 3x2 caballero

Ask a CCO: How do you prevent whistleblower retaliation?

2021-10-06T13:00:00+01:00By Compliance Week

Seven senior compliance practitioners detail the steps their respective companies take to ensure whistleblowers are not retaliated against when reporting potential misconduct.

Taro Pharmaceuticals

Compliance implications of drugmakers’ $447M False Claims Act settlements

2021-10-05T19:26:00+01:00By

Three pharmaceutical manufacturers—Taro Pharmaceuticals USA, Sandoz, and Apotex Corp.—will pay a total of $447.2 million for alleged violations of the False Claims Act related to price-fixing.

Nicodemus_opinion

Lessons learned from actions of Facebook whistleblower Frances Haugen

2021-10-05T16:09:00+01:00By

Many whistleblowers are forced to take their complaints outside the company because their attempts to address the problems internally are rebuffed or ignored. Facebook is paying the price for that inaction.

ask cco 3x2 katz

Ask a CCO: What makes a good internal reporting system?

2021-10-05T13:00:00+01:00By Compliance Week

Seven senior compliance practitioners explain what they believe to be the key tenets of an internal reporting system that encourages employees to come forward with reports of potential misconduct.

ask cco 3x2 carrington

Ask a CCO: How do you encourage internal reporting?

2021-10-04T13:00:00+01:00By Compliance Week

Seven senior compliance practitioners share how they encourage employees to come forward with reports of potential misconduct in support of the greater mission of instilling a culture of compliance.

SEC

Red flags ignored in WPP $19M FCPA settlement

2021-09-24T19:34:00+01:00By

Global advertising giant WPP reached a more than $19 million settlement with the SEC to resolve charges of violating the anti-bribery, books and records, and internal accounting controls provisions of the Foreign Corrupt Practices Act.

Remote oversight

Anti-corruption leaders share upsides of remote compliance program

2021-09-23T17:05:00+01:00By

COVID-19 has altered how companies operate their anti-corruption compliance programs, but not necessarily for the worse, according to experts from PepsiCo and Cook Group who shared their experiences at a recent Diligent virtual summit.

GameStop sign

MassMutual $4M fine a lesson in trader conduct oversight

2021-09-17T15:24:00+01:00By

A subsidiary of Massachusetts Mutual Life Insurance agreed to pay $4 million after apparently missing nearly two years’ worth of red flags by one of its broker-dealers that turned out to be a driving force behind the GameStop stock trading craze.

Accounting coronavirus

Study: How COVID-19 has affected public company financials

2021-09-10T12:23:00+01:00By

Disruptions to normal operations and shifts in work environments as a result of the COVID-19 pandemic caused an increase in late filings and changes to controls, according to new research from Audit Analytics.

SEC office

SEC fines Healthcare Services Group $6M over contingency reporting lapses

2021-08-24T20:55:00+01:00By

Healthcare Services Group agreed to pay $6 million as part of a settlement with the Securities and Exchange Commission for contingency reporting failures that led to accounting and disclosure violations.

Whistle

BSI guidance offers whistleblower management best practices

2021-08-23T17:54:00+01:00By

The British Standards Institution has created international guidance to help companies set up an effective whistleblowing management system.

Business challenges

Benchmark report explores roadblocks for leadership commitment to compliance

2021-08-16T14:28:00+01:00By

Most risk and compliance professionals feel their senior leaders and managers demonstrate a commitment to their programs overall, but only on a conditional basis, according to the latest NAVEX Global benchmark report.

BitMEX

Crypto platform BitMEX to pay $100M for registration, AML violations

2021-08-11T15:45:00+01:00By

Cryptocurrency platform BitMEX has agreed to pay $100 million as part of a settlement with the CFTC and FinCEN for multiple violations of the Bank Secrecy Act and other anti-money laundering laws.

Investigations

What factors are driving change in your corporate investigations process?

2021-08-10T15:00:00+01:00By

A recent survey from Compliance Week and OpenText reveals while investigations and data volumes are on the rise, machine learning combined with external expertise may give companies the upper hand in accelerating response and results.

Whistle question

Five pieces of advice for potential whistleblowers

2021-08-05T15:56:00+01:00By

Thinking of becoming a whistleblower? The path ahead likely won’t be easy. Learn from others that have been through the process.

Business agreement

Seven things whistleblowers want compliance officers to know

2021-08-04T17:54:00+01:00By

Aaron Nicodemus explains what whistleblowers, their supporters, and advocates would like compliance officers who handle internal complaints to understand about the process from their side of the table.

European Commission

EU guidance seeks to clarify role of AML/CFT compliance officers

2021-08-04T16:38:00+01:00By

The European Banking Authority is seeking comment on new draft guidelines that set clear expectations regarding the appointment, role, tasks, and responsibilities of anti-money laundering and countering the financing of terrorism compliance officers.

Whistleblower Day

Three ideas to improve the whistleblowing process

2021-07-30T13:00:00+01:00By

It’s important to take stock of how far whistleblowing has advanced over the last few years. That said, there is still room for improvement. Aaron Nicodemus offers three suggestions.

Jeffrey Smith

Part 5: Waiting for payout a grueling test of tenacity for whistleblowers

2021-07-30T13:00:00+01:00By

The road to a payout for whistleblowers is long, lonely, and full of obstacles. Commitment to the idea that they are doing the right thing helped our whistleblower subjects endure years of hardship to bring their cases to conclusion.

Credit Suisse sign

Report: Deficient risk culture at Credit Suisse contributed to Archegos collapse

2021-07-29T17:00:00+01:00By

An independent report commissioned by Credit Suisse to examine the bank’s failures that led to $5.5 billion in losses when Archegos Capital Management collapsed this year concluded a series of missteps by risk and compliance failed to escalate numerous red flags.

Andrew Russo

Part 4: Retaliation pervades while whistleblowers persevere

2021-07-29T13:00:00+01:00By

Retaliation for blowing the whistle comes in all kinds of forms. Our whistleblower subjects share their stories—from losing jobs to getting blacklisted to being the target of a newspaper hit piece.

Dee Dee Stone

Part 3: Blowing the whistle weighs uncertainty against moral duty

2021-07-28T13:00:00+01:00By

Once someone decides to blow the whistle, their life is forever changed. Their action stands to benefit many people they don’t even know while putting much in jeopardy on a personal level. Our whistleblower subjects each explain what led them to their determinations.

Brendan Delaney

Part 2: Internal reporting sends whistleblowers down path alone

2021-07-27T13:00:00+01:00By

Almost no one becomes a whistleblower by choice. A slow and steady whittling down of options often leads individuals to isolation in coming to their decision. Our whistleblower subjects share the roadblocks they faced in reporting internally.

ESGReporting

What companies (and the SEC) can learn from U.K. ESG reporting guidance

2021-07-26T16:39:00+01:00By

The U.K. Financial Reporting Council has proposed a series of measures from which companies—as well as other regulators like the SEC—could benefit as ESG disclosures receive closer scrutiny.

Aaron Westrick

Part 1: Finding the fraud launches whistleblowers on life-changing journey

2021-07-26T13:00:00+01:00By

Whistleblowers aren’t born—they’re made. For five individuals that have taken on that mantle, the story began with discovering a problem that could no longer be ignored.

SEChq

ICFR failures cost Tandy Leather in SEC settlement

2021-07-21T16:28:00+01:00By

Tandy Leather Factory and its former CEO have agreed to pay a total of $225,000 as part of a settlement with the SEC to resolve charges of inaccurate financial reporting caused by a faulty inventory tracking system.

Credit Suisse

Credit Suisse creates new risk role to prevent next Archegos

2021-07-12T17:32:00+01:00By

Credit Suisse has named Amélie Perrier to a new senior executive position to track the trading positions of its largest customers after the bank lost $4.7 billion in the aftermath of the collapse of Archegos Capital Management.

AdobeStock_314226034

Five steps to elevate your average compliance program

2021-07-12T16:38:00+01:00By Joe Murphy, CW guest columnist

Why settle for an average compliance program when you can have so much more? It isn’t easy, but commitment to a handful of key requirements can push your program to the next level.

Charles Duross

Charles Duross: Tips for managing third-party FCPA risks

2021-06-30T21:00:00+01:00By

Charles Duross, former deputy chief of the DOJ’s Fraud Section, shared tips on how companies can best manage third parties and employees who willfully try to circumvent internal controls during his keynote speech at CW’s virtual TPRM conference.

archive360 300x200

CPE Webcast: Long-term data retention and archiving strategies for regulatory compliance

2021-06-24T14:00:00+01:00Provided by

As the volumes and types of electronic data generated by organizations continues to grow, it becomes increasingly complex to correctly identify, capture, store, protect and make searchable hundreds of terabytes (or petabytes) of disparate data.

Brasseur_opinion

Distinction between CCO and company key to any liability framework

2021-06-22T13:44:00+01:00By

Despite best effort, a chief compliance officer has a lot to lose when his or her company faces enforcement. Acknowledging this as part of any potential CCO liability framework will be important to its success.

Deutsche Bank

Embattled Deutsche Bank to overhaul anti-financial crime controls

2021-06-16T20:26:00+01:00By

Deutsche Bank is planning to shake up its internal structure around anti-financial crime efforts in the wake of criticism from multiple regulators.

Globe

How global compliance works at the local level

2021-06-11T16:30:00+01:00By David Povey, International Compliance Association

For compliance officers working for global companies, it is important to understand the way different regions view compliance and how it may differ from your home country’s views.

Coronavirus look ahead

‘Cost of Compliance’ survey reflects post-COVID landscape

2021-06-07T20:02:00+01:00By

A year removed from the start of the pandemic, the long-term effects the shift in work culture will have on the compliance profession have become more apparent. The “Cost of Compliance Report 2021” by Thomson Reuters reflects these changes.

Culture

Compliance changing culture requires proactive collaboration

2021-06-07T13:59:00+01:00By Jonathan Dempsey, Red Laces, for International Compliance Association

Compliance teams might recognize opportunities for changing culture. To do so, they need to adapt readily in both purpose and approach and embrace innovation.

Bistrong_opinion

My Compliance Library: ‘To Be Honest’ a roadmap to address organizational disunity

2021-06-04T15:18:00+01:00By

Ron Carucci’s book “To Be Honest” enables everyone in an organization to build “honesty as a muscle” and to operationalize aspirational goals and principles into an individual and group ethical capacity.

VW Drive Bigger

Chapter 5: Volkswagen’s path to winning back trust

2021-05-20T13:00:00+01:00By

Its monitorship now complete, Volkswagen’s new focus is to rebuild its reputation among its customer base. It’s a long process, says Board Member Hiltrud Werner, one supported by a shift in strategy.

VW group board

Chapter 4: Tangible measures of cultural progress at Volkswagen

2021-05-20T13:00:00+01:00By

At the end of the day, how does an organization measure the effectiveness of company-wide cultural initiatives? Volkswagen has answers, utilizing perception workshops, mood barometers, and new diversity and inclusion initiatives as part of its culture rebuild post-Dieselgate.

ESG_corrected

Compliance ‘well-situated’ to handle increasing ESG scrutiny

2021-05-19T15:30:00+01:00By

An expert panel at CW’s 2021 National Conference agreed that compliance is uniquely positioned to help companies in their ESG initiatives. The CCO and chief sustainability officer at FedEx share how this may look in practice.

Volkswagen T4I key initiatives

Chapter 3: VW operationalizes its Dieselgate monitorship

2021-05-19T13:00:00+01:00By

A revamped code of conduct and the Together4Integrity campaign stood out as significant milestones for Hiltrud Werner & Co. as Volkswagen began to embrace its Dieselgate monitorship as a way to improve company culture.

Hiltrud Werner index

Chapter 2: Volkswagen monitorship falls in line under Hiltrud Werner

2021-05-18T13:00:00+01:00By

While Larry Thompson assembled his team for the Dieselgate monitorship, Volkswagen countered with appointments of its own, including Hiltrud Werner as head of integrity and legal affairs. Their relationship would determine the success of the monitorship going forward.

Diesel emissions

Chapter 1: Volkswagen’s Dieselgate scandal exposed; enter Larry Thompson

2021-05-17T13:00:00+01:00By

The Volkswagen Dieselgate scandal wasn’t the work of one executive who thought to install illicit software into diesel motor vehicles. It was born from a “chain of errors that was never broken,” forming the basis for one of the largest and most high-profile corporate compliance monitorships in history.

Dirty window

CW presents: ‘Coming Clean: Volkswagen’s Dieselgate scandal and compliance monitorship’

2021-05-17T13:00:00+01:00By

Volkswagen’s recently concluded three-year monitorship is chronicled in CW’s latest in-depth case study, which spares no detail in following the world’s largest automaker’s comeback from its biggest mistake.

Reporting DEI CW2021

Cooperation key to compliance’s role in advancing diversity & inclusion

2021-05-13T19:24:00+01:00By

A panel of DE&I experts shared valuable tips on how chief ethics and compliance officers can work collaboratively with human resources to address workplace culture issues at CW’s 2021 National Conference.