Shows
Compliance BeatThree Helpful Compliance Data Points from the US Sentencing CommissionIn this episode Eric discusses the upcoming SCCE CEI event in Las Vegas (20th Annual Compliance & Ethics Institute | SCCE Official Site (corporatecompliance.org)), and in particular, one of the sessions he will be co-presenting with Kathleen Grilli from the US Sentencing Commission, "Thirty Years of Organizational Sentencing Guidelines: Looking Back and Looking Forward". In particular, Eric discusses three data points from the USSC's dataset (Sourcebook 2020 | United States Sentencing Commission (ussc.gov)) that could be especially useful for compliance professionals when discussing real-world consequences for compliance failures.2021-08-2027 minCompliance BeatThree Considerations When Launching a New Code of ConductIn this episode Eric discusses some considerations for a successful code of conduct launch. Often organizations spend a lot of time, effort and resources on revising and improving their code of conduct only to have little in the way of a launch effort. Eric discusses some ideas to avoid a failure to launch.2021-06-1415 minCompliance BeatWe're Back! Re-Introduction to Compliance Beat PodcastAfter a extended hiatus, we're back! We're looking for your feedback on what to cover and what you'd like to hear about in the weeks going forward. Email us at: eric@moreheadconsulting.com2021-06-0103 minCompliance Beat3 Changes and 3 Things That Will Remain the Same for Compliance after CovidIt's been a year! We've seen challenges and changes -- and we're still not completely out of the woods yet. In this episode Eric talks about three of those seemingly permanent changes that compliance and ethics programs have had to deal with and also discusses three things that are definitely not going to change.2021-06-0121 minCompliance BeatCompliance in the Age of Coronavirus: Tips for Remote ComplianceThe world has changed since our last episode. Eric has some ideas for newly remote compliance officers handling newly remote workers. Communication is key, and the compliance team needs to make a special effort to be heard and involved.2020-04-0920 minCompliance BeatThree Reasons to Hire a Third Party for an AssessmentThis time Eric discusses three primary reasons an organization might want to work with a third party to conduct a compliance program assessment.2020-03-1213 minCompliance BeatKeys to Benchmarking Your Code of ConductThis time Eric walks through some categories to benchmark your code of conduct. Organizations are expected to regularly examine the effectiveness of their written standards and there are some common areas to review when taking stock of your code.2020-03-0617 minCompliance BeatThree Keys for Conflicts of Interest ComplianceThis time Eric discusses three keys for a successful conflicts of interest compliance process. Eric discusses communication, disclosure, certification and tools that organizations can use to better address conflicts of interest risk.2020-02-2017 minCompliance BeatThree Essential Components for a Compliance Program AssessmentThere are many ingredients for a successful compliance program assessment, but in this episode Eric focuses on three key components that are sometimes overlooked when an organization is either conducting their assessment internally or looking to a third-party to help them with a review.2020-02-0712 minCompliance BeatThree Myths About Anonymous Reporting MechanismsThis time Eric talks anonymous reporting mechanism. What is actually required? What does reporting data show an compliance officer? What is the most effective reporting channel for an organization? We talk about these important questions and debunk a few myths about anonymous reporting.2020-01-3122 minCompliance BeatThree Questions to Ask Before You Start Your Compliance Communication ProgramThis time Eric spends some time talking about some practical considerations for organizations to consider when planning or revising their "informal" compliance communication program. This area of compliance has been changing quite rapidly and expectations are often high. To avoid disappointing results it is important for compliance officers and others charged with communication responsibilities to carefully consider the goals and realities of proposed program.2020-01-1021 minCompliance BeatPerception and Retaliation, Part IThis time Eric talks about retaliation. What does retaliation look like in an organization? How does perception of retaliation affect reporting? We spend a few minutes looking at the data and discussing what you should expect at your organization.2019-12-1022 minCompliance BeatInvolving Managers in Compliance:Getting your managers involved in your compliance program is a best practice and also the most effective way to address compliance culture locally. In this episode Eric talks about three key criteria to consider when putting together a plan for involving managers: training, resources and measurement. Eric discusses some practical ways to implement such a plan.2019-11-2030 minCompliance BeatSentencing Commission Confidential – Origins of the HallmarksAs more and more compliance professionals join the ranks from other disciplines, it’s important that we reinforce the role of the US Sentencing Commission, and maybe even more importantly, the public’s role in defining the compliance and ethics standards all of our programs are based on.
Listen to a short description of what the Sentencing Commission is, and their role in our profession — both past and future.
Also, join Eric for a webinar next week on Thursday, November 7th at 1PM ET: Updating Your Code of Conduct: Best Practices.
2019-11-0132 minCompliance Beat2019 SCCE Compliance and Ethics Institute PreviewEric spends a few minutes looking back at CEI’s past — and talking about the threads and new trends in this year’s event. If you are visiting DC this week then come by and see Eric at Booth 106. If not, we hope to see you next time!
https://www.corporatecompliance.org/conferences/national/18th-annual-compliance-ethics-institute-2019
“SCCE’s annual Compliance & Ethics Institute is the primary educational and networking event for compliance professionals across all industries around the world. Each year we host more than 1,600 attendees from 40 countries.”
2019-09-1522 minCompliance BeatPrivacy Bulletin: A Discussion on Privacy Compliance with Teresa Troester-Falk (PART II)This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California, potential new laws in several states, and how it relates to GDPR and privacy compliance generally. This is the Second part of a two part conversation. If you haven’t listened to Part I we encourage you to do so.
Teresa is Chief Global Strategist for Nymity where she leads some of Nymity’s key accountability research initiatives and collaborates with other internal leaders to help innovate privacy accountability and compliance solutions and ensure organizational success. Teresa authors Nymity white papers and othe...2019-09-0725 minCompliance BeatPrivacy Bulletin: A Discussion on the California Consumer Privacy Act and Privacy Compliance with Teresa Troester-Falk (PART I)This time Eric is Teresa Troester-Falk to discuss the pending new privacy law from California and how it relates to GDPR and privacy compliance generally. This is the first part of a two part conversation. Join us next week for part two.
Teresa is Chief Global Strategist for Nymity where she leads some of Nymity’s key accountability research initiatives and collaborates with other internal leaders to help innovate privacy accountability and compliance solutions and ensure organizational success. Teresa authors Nymity white papers and other publications and regularly speak at conferences, advanced privacy forums and on webinars. Te...2019-08-3124 minCompliance BeatSentencing Commission Confidential: Who Speaks To The Board?This time, in anticipation for a Sentencing Guideline presentation next month at the SCCE’s CEI in Washington DC, we have another belated edition of Sentencing Commission Confidential. Eric talks about a commonly overlooked or misunderstood part of Chapter Eight of the guidelines that sets out responsibilities for reporting to the Board (or governing authority) of an organization. If you or your organization still struggles with what that conduit to the Board should look like, take a listen. Eric references parts of Chapter Eight of the guidelines which can be found here.
2019-08-1719 minCompliance BeatThree Key Components for a Compliance Program AssessmentThis time Eric discusses compliance program assessments – or risk assessments – or program benchmarking – or whatever you want to call the periodic review of your program that the Sentencing Guidelines, USDOJ guidance and best practices call for. Eric discusses three key pieces of the puzzle you might want to consider whether you are undertaking the assessment internally or evaluating outside assistance.
Eric mentions Chapter Eight of the Sentencing Guidelines in the podcast, the text of which can be found here.
2019-08-0316 minCompliance BeatDo We Need Compliance Expertise on the Board?One of the questions raised by the recent updated USDOJ guidance is the question of “expertise” at or on the board of directors. Eric takes some time this week to discuss the guidance and the practical considerations about expertise in the boardroom.
If you are interested in the intersection of compliance and the board of directors, please join Eric for a webinar on the topic July 31st at 1PM ET. “What Should Your Board Know About Compliance and Ethics?” click here for more information.
2019-07-2019 minCompliance Beat3 Tips for an Excellent (Formal) Informal Communication ProgramOne of the areas many compliance teams still struggle with is getting a consistent, effective informal communication plan off the ground. Eric has a few ideas that might help focus informal communication efforts at your organization. Eric talks about being realistic regarding time and resources and thinking strategically about what might reach your audience.
2019-07-1325 minCompliance BeatNew USDOJ Guidance – Part 9 – Incentives and DisciplineIn Part 9 of our special series discussing the new memo from the US Department of Justice on compliance expectations, Eric finishes discussing Part II of the memo with a review of incentives and discipline expectations.
Check out the memo itself here: https://www.justice.gov/criminal-fraud/page/file/937501/download
Also, check out Eric “live” in Houston on June 20, 2019 – Hosted by the Federal Bar Association, Southern District of Texas Chapter, June 20,
“The DOJ’s New Compliance Guidance:Answering the Three Key Questions”.
AND, check out the upcoming webinar on June 19, 2019 at 3PM ET/ 2PM CT: “Crea...2019-06-1216 minCompliance BeatThree Myths About Code of Conduct DevelopmentEric talks again about his favorite topic: code of conduct! This time we discuss three common code of conduct development myths. We talk about how longer does not equal better. How a global code that applies to everyone is better than a constellation of many codes. And finally Eric discusses how organizations should be realistic about the time and resources that go into a successful code of conduct project.
2019-04-1716 minCompliance BeatDisclose, Disclose, Disclose: Some Thoughts on Conflict DisclosuresThis time Eric talks through conflicts of interest disclosures. Who do you want to capture, what do you need to tell them, should you use tools? Eric talks through all of this and also spends some time talking about the types of questions you will want to ask in the disclosure questionnaire.
Join Eric and the Clear Law Institute for another addition of his Code of Conduct Development webinar on April 4th 2019 at 1PM ET. You can register for the webinar here.
2019-03-2922 minCompliance BeatBenchmarking Your Code or Written Compliance StandardsThis time we discuss benchmarking. First we discuss how you might go about determining the peer codes of conduct (or other written compliance standards) that you can use for benchmarking purposes. You probably have a good idea of some peer organizations that might fit, but Eric also discusses some other thoughts about what gets put into the mix. Then we discuss some different areas and criteria you might want to consider when evaluating your written standards and comparing them to other written standards. We talk about content and presentation as well as different, specific content you want to be...2019-02-2627 minCompliance BeatThree Questions to Ask Before You Launch a Compliance SurveyThis time Eric talks about compliance surveys. Eric discusses what sort of content you might consider including in the survey instrument, whether you might want to consider benchmarking, and finally Eric discusses some of the practical elements of putting together a survey.
2019-02-1613 minCompliance BeatStrategies for Reaching Remote WorkersThis time Eric talks about three different areas to focus on when evaluating how you are reaching your remote workers to educate and inform them of the compliance program. Eric discusses use of local and existing resources, what resources should be developed by the compliance function and how technology can be put to use.
Eric is also speaking at SCCE’s Energy and Utilities Conference in Houston on February 11th. Join us there if you can!
2019-02-0725 minCompliance BeatHow Should the Board Be Involved in Compliance?This time Eric discusses some considerations when looking at the role, responsibilities and relationships the board (or governing authority) of the organization with the operational personnel of the compliance and ethics program. There are a few key best practices to consider when evaluating the board’s role, including their training and knowledge of their responsibilities, their understanding of compliance risks and controls and their relationship with operational compliance.
Also, Eric mentions his upcoming speaking role at the SCCE’s Utilities Conference in Houston, February 10-12, 2019. If you are interested in attending, information is here.
2019-01-2616 minCompliance BeatHow to Avoid All Compliance Risk…How do you avoid all compliance risk? Hint: you can’t. This week Eric talks about some recent articles and discussions that suggest there might be a magic bullet or two (sometimes in the form of a new software tool) that will take away those pesky compliance concerns. We alk about the practical and the pragmatic view of this topic.
Also, please join us next week for a webinar on developing your code of conduct. We’re putting the webinar on with our friends at the Clear Law Institute on January 17th at 3PM ET. If you are...2019-01-0816 minCompliance BeatYear-End Review, Part II: Compliance Program TrendsHappy Holidays from Compliance Beat!
This week Eric discusses a few compliance program trends from the last year in the second of a two-part series here as we end 2018. This time Eric discusses leveraging opportunities, being part of the deal team and gaining better access to the board.
We have another upcoming webinar with our friends as the Clear Law Institute on January 17th at 3PM ET. If you are interested in joining us for “Updating Your Code of Conduct: Best Practices” you can register here.
2018-12-2718 minCompliance BeatYear-End Review, Part I: Compliance Program TrendsHappy Holidays from Compliance Beat!
This week Eric discusses a few compliance program trends from the last year in the first of a two-part series here as we end 2018. This time Eric discusses interesting developments in communications, data use and proactive risk assessment.
We have another upcoming webinar with our friends as the Clear Law Institute on January 17th at 3PM ET. If you are interested in joining us for “Updating Your Code of Conduct: Best Practices” you can register here.
2018-12-2122 minCompliance BeatWhat is Monitoring and Auditing in an Effective Compliance and Ethics Program?This week Eric talks about one of the hallmarks of the Sentencing Guidelines that is sometimes overlooked or not as carefully understood. Monitoring and auditing is sometimes reduced to reporting, but it is so much more. To guide us on the journey, Eric reviews the language and notes in the Sentencing Guidelines themselves and discusses the Department of Justice’s most recent guidance on the topic.
Eric refers to both Chapter 8 of the Guidelines, which you can find here, and the February 2017 memo from DOJ, “Evaluation of Corporate Compliance Programs,” which you can find here.
2018-11-2926 minCompliance BeatRoy Snell Interview, Part I & Three Components to Board TrainingThis time Eric has a very special guest, and our first guest to appear twice, Roy Snell. Roy was on the 2nd Episode of Compliance Beat back in 2016 and he has graciously joined us again just as he is leaving his role as the CEO of the HCCA and the SCCE. In this episode Eric and Roy talk a little about the past and the present of the compliance profession and SCCE as Part I of the interview. Tune in next week to hear Roy’s thoughts about the future of compliance in Part II.
Eric also sp...2018-11-0733 minCompliance BeatThree Compliance Communication IdeasWe’ve been away and had some technical difficulties with our Compliance Beat website — but we’re back!
You can’t keep a compliance podcast down!
This week Eric talks about three creative ways to approach one of the more esoteric parts of an effective compliance program: informal communications.
Eric talks about thinking outside the box, using activities and integration with other messages — and provides examples.
2018-11-0123 minCompliance BeatTowards a Universal Code of ConductThis time Eric talks about three components that every code should have to be universally accepted by the organization’s stakeholders. First, the code should apply to everyone, from the top of the organization to those third parties that represent the organization. Second, there should be one code. Organizations that still have regional codes or different codes for different business units need to abandon this practice. Third, seriously consider making your waiver section a NO WAIVER section. If you have provisions you fear may need to be waived, you need to examine why that would be and whether that pr...2018-10-1119 minCompliance BeatBaylor University… Again: How The Four Rules of Crisis Management ApplyEric revisits the (still) ongoing issues surrounding misconduct, governance, compliance and crisis management that swirl around Baylor. After first discussing the different paths that Baylor and Penn State, for example, took back in our Compliance Beat Podcast in December 2016, we are still discussing the path that Baylor has taken — and the paths that lay untrodden. Eric also talks about two upcoming webinars you can participate in. One, Bullying in the Workplace: A Comprehensive Ethics & Compliance Overview, on October 18th can be registered for here, and a second, Updating Your Code of Conduct: Best Practices, on October 26th, has a re...2018-10-0420 minCompliance BeatCrisis! Four Rules for Crisis Management and Compliance’s RoleThis week Eric talks crisis management, and in particular, Steve Denning’s Four Rules of Crisis Management. We talk about how the role of compliance intersects to crisis situations. Eric also talks about two upcoming webcasts, one Bullying in the Workplace: A Comprehensive Ethics & Compliance Overview will be on Thursday, Oct 18th at 1:00 PM EDT — the registration link is not yet up — but we will follow-up with more info as it becomes available. The second webinar is Updating Your Code of Conduct: Best Practices which you can sign up for here and will be on October 26th at 1PM EDT. A...2018-09-2621 minCompliance BeatThree Arguments for Compliance (Budget)This time Eric walks through three different areas to consider when making the case internally for compliance resources or specific compliance initiatives. We discuss three different areas to cover, regulatory or risk issues, empirical data and benchmarking and making the functional business case. Eric provides a few examples and talks about how having a well-rounded argument will help with your stakeholders.
2018-08-3013 minCompliance BeatTom Fox Discusses His Complete Compliance HandbookThis week we have a special guest, Tom Fox, who discusses his new book “The Complete Compliance Handbook” with Eric. You can find out more about the new book, and how to order it, here.
Also, don’t forget to join us and our friends at SAI Global for a FREE webinar (with 1.2 CCB CEU’s approved for your CCEP) on Thursday the 24th at 10AM CT / 11AM ET entitled “Cracking the Code: Understanding Regulatory and Stakeholder Expectations for Code of Conduct” — you can register (FOR FREE) here.
And, as always, don’t forget to subscribe to the...2018-05-2217 minCompliance BeatHow Do You Benchmark Your Code of Conduct?This week Eric addresses a common question: how do you benchmark a code of conduct?
Eric focuses on three key areas to have a more successful benchmarking project. First, we talk about how you want to include peer codes outside your organization’s industry. Second, Eric discusses the fact that you don’t need to find “all things” in each code in your review. Find aspects you like in several codes, whether that’s content, design, language use, navigation. Find what you like, and include it. Lastly, we discuss how you need to include the team. Have a cross-fu...2018-04-0315 minCompliance BeatDo Regulators Still Care About Compliance?Since 2016 we have heard this question frequently. The popular media, particular in the United States, has championed the idea that “regulation” is disappearing. But, in the context of compliance expectations, is that really true? Eric takes a look at three different reasons why that might not really be the case. In these days when regulator expectations regarding compliance are still high, and popular notions about compliance may be sinking, it’s important for those who are responsible for compliance to have a handle on these issues and be ready to answer these questions.
Eric also would like for yo...2018-03-2617 minCompliance BeatWhat Makes an Effective Conflicts of Interest Compliance Program?This time Eric talks about three aspects of an effective response to conflicts of interest. First, we discuss written standards and how a code of conduct and other materials can interplay effectively to provide helpful resources on conflicts. Second, Eric discusses disclosures, the piece of the puzzle that many organizations still do not include in their program. Eric discusses a little on how to deploy a disclosure process and what content questionnaires should include. Finally, we discuss generally what you’ll want to cover with training and communication.
Eric also mentions a new FREE webinar that we wi...2018-03-2025 minCompliance BeatWhat Does Monitoring Mean in a Compliance and Ethics Program?This week Eric tackles what “monitoring” means in the context of a compliance and ethics program. We break it down into three main concepts. First, applying a “risk-based” process to monitoring means understanding your risks, applying those controls you have (including monitoring) and then evaluating those controls for effectiveness. Second, Eric spends a little time talking about the processes, tools and systems that generally comprise compliance monitoring. Finally, Eric talks about the important “feedback loop” of monitoring data that helps an organization spot trends and issues and improve their monitoring — and their entire program.
2018-03-0717 minCompliance BeatWhat is a Risk-Based Compliance Training Program?This time Eric discusses what makes a “risk-based” training program. Many organizations are in the thick of getting ready to roll out their training this spring, and it’s a good time to consider what you do to train your stakeholders on compliance risks. We talk about the February 2017 Evaluation of Corporate Compliance Programs memo from the Fraud Section at the Department of Justice. In particular, we focus on how recent guidance talks about “tailored” training programs, how we must focus on the training program process at the front AND back ends, and Eric also talks a little about the use of...2018-02-2720 minCompliance BeatThree Things to Consider Regarding Compliance and Crisis EventsEric, like a lot of people in the USA this Spring, is getting over a unexpected bout of the flu. It got him thinking about compliance during crisis events and how compliance interacts with business continuity planning. We spend some time talking about some ways compliance should be involved.
Apologies for the poor sound quality this week — Eric will be back about a whisper next week with a new topic!
Now Eric is going to rest and get some fluids. But please check out the webinar he’s giving on February 28th at 3PM ET on C...2018-02-2018 minCompliance BeatWhat Makes a Good Written Compliance Policy?This time we focus on the next horizon for “effective” written standards: the stand-alone compliance policy. While many organizations have tackled their code of conduct, written policies still woefully suffer from some of the same ailments we’ve cured in our codes. Eric takes time to talk about the differences between a code project and getting your arms around written policies, including the challenges with different stakeholders. We then discuss three different areas to keep in mind when starting a policy revision process.
For those interested in revising policies or code of conduct, Eric is leading a webina...2018-02-1219 minCompliance BeatThree Things To Consider About Creative Compliance CommunicationIt’s that time of the year when compliance professionals are dusting off their annual plans for the program. That nearly always includes planning for training, but less often does it include detailed plans for communications.
In this episode Eric talks about the US Sentencing Guideline standards and expectations regarding communication and then he provides three good areas to concentrate on.
First, we talk about having a written plan and what that communications plan might look like. Second, Eric discusses some different ways organizations can be more creative regarding their compliance communications. And lastly, Eric di...2018-01-3022 minCompliance BeatThree Code of Conduct Project Pain PointsToday Eric talks about three common areas he has seen clients experience issues when they undertake to update their code of conduct. First, Eric discusses getting the appropriate buy-in from all the applicable stakeholders. Involving the team and making sure everyone shares the appropriate vision is critical and failure can sometimes derail a project.
Next we discuss apportioning the right project management to make sure that the job gets done and gets done efficiently.
Finally, we discuss proper scoping. Organizations very often underestimate — or fail to estimate at all — what the update to their code will...2018-01-2319 minCompliance Beat10 Things To Know About the EU General Data Protection Regulation (GDPR)This week Eric speaks to a Top Ten list, if you will, of topics to consider regarding the upcoming implementation of the EU’s new General Data Protection Regulation (GDPR). As with most compliance issues, small and medium sized organizations are likely to be the ones that are least prepared for this change, and a recent survey shows that almost one quarter of US companies hadn’t even heard about the new regulation. Since GDPR has a more expansive jurisdiction, it also will potentially cover many more organizations. Listen in as Eric walks through 10 things to consider when getting read...2018-01-1633 minCompliance BeatThe Road Ahead: 2018 Compliance TrendsAfter finishing another year we now embark on 2018 — and another yearly edition of trend predictions. In this episode Eric talks about a couple of key compliance risk topics that organizations will want to think about as they plan out their new year, including some significant changes that will be happening soon. We also discuss some of the new guidance we have seen at the end of the year and the possibility of new guidance as the new year progresses. Finally, Eric also discusses how to balance the rhetoric about deregulation with the realities of continued enforcement and how compliance pr...2018-01-0831 minCompliance BeatReflecting on the SCCE’s Compliance and Ethics InstituteThis time Eric reflects on the annual SCCE Compliance and Ethics Institute in Las Vegas.
While there are certainly other compliance and ethics events, the size and scope of the CEI is impressive and we noted three themes this year that apply not to just CEI, but the profession in general.
First, growth — and all that brings — including challenges. What does this mean and how does that apply to the role of compliance?
Second, we face a lot of uncertainty. But while organizations face a lot of regulatory uncertainty, and uncertainty generally, Eric talk...2017-11-0620 minCompliance BeatThree Things To Know About Third-Party RiskToday Eric talks about third-party risks and some ideas for every organization to think about when thinking about third-party risk.
First, we encourage everyone to think outside the box and contemplate the actual third-party risks that their specific organization faces. We often think third-party risk just applies to organizations that operate overseas or have anti-corruption risks. Third-party risks are much broader and organizations should take time to consider it.
Second, Eric talks about how third parties are the “perfect storm” for risk. It’s hard to imagine any organization these days that doesn’t have third-pa...2017-10-2721 minCompliance BeatCompliance & Ethics Institute Preview with SCCE’s Adam TurteltaubThis week, we prepare to go to the annual SCCE CEI in Las Vegas. Recent events make the trip more somber, but we look forward to seeing old friends and meeting new ones. Eric speaks with SCCE’s Adam Turteltaub to discuss what’s new this year at the Compliance and Ethics Institute and some of the thought that goes into planning and organizing the annual event.
Eric also talks a little about the concept of “right action” and moving forward with your goals despite conflict.
It was a year ago that we launched Compliance Beat as w...2017-10-1032 minCompliance BeatWhat’s the ‘Bare Minimum’ Needed for Compliance? Part IIWhat is the “bare minimum” an organization needs to have an effective compliance program? Today we have part II of our discussion of what minimum requirements for an effective compliance and ethics program might be.
Eric talks a little about the focus on organizational guidelines versus the Sentencing Guidelines as a whole. Eric also talks about the importance of reading the guidelines yourself and looking at the nuance of the standards themselves.
We pickup where we left off, discussing the last three hallmarks of the “Seven Hallmarks”.
Eric talks about monitoring and auditing, and how t...2017-10-0327 minCompliance BeatWhat’s the ‘Bare Minimum’ Needed for Compliance? Part IWhat is the “bare minimum” an organization needs to have an effective compliance program? Is that even the right question? Eric talks about a common inquiry that people often have about the “Seven Hallmarks” of the Sentencing Guidelines, and that is: what must we do? In Part I of a two-part series, Eric talks about how the Guideline standards are really the floor for expectations. We spend some time also talking about the guidance in the Guidelines, in particular the importance of the Application Notes of the Guidelines that are often overlooked.
Eric also discusses the treatment of differe...2017-09-2525 minCompliance BeatEffective Board of Directors Training, Part IIYour board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge.
In this second part of a two-part podcast series, Eric again speaks to how can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members and follows up the previous episode with two additional areas of training you should con...2017-09-1722 minCompliance BeatEffective Board of Directors Training, Part IYour board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. How can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members, both new and old? What is the source law and standards for director’s responsibility for compliance? What risks do they face for not being on top of these responsi...2017-09-1223 minCompliance BeatWhat Are Some Corporate Enforcement Myths?This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way. Eric talks about what we really are seeing with enforcement and the statements coming from regulators and prosecutors, including the USDOJ. Eric also points out the long lead times for investigations and actions means that we are unlikely to see this effect anytime soon. Additionally, it’s important to remind ourselves that the costs associated with misconduct issues, internal investigations and ongoing enforcement inquiries can pile up. Er...2017-09-0520 minCompliance BeatShould We Measure Our Case Management and Reporting System? What Are Some Ways to Measure?This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case put together so that you can budget for tools in the first place. We also talk about how “effectiveness” is not a black box and applies to everyone. Expectations include those detailed in the most recent DOJ guidance. Measurement should look at the process you have in place. What’s the plan and how is i...2017-08-2818 minCompliance BeatA Special Conversation with Ricardo PellafoneIn this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including, how having a lot of resources and being very busy does not necessarily equal an “effective” program. As Ricardo paraphrases Hui Chen: “doing more is not better, smarter is better”. They also discuss how compliance really must conform to the same business and effectiveness measures as any other part of the organization. Ricardo also talks about the business case for compliance and Eric talks about some con...2017-08-2137 minCompliance BeatWho Should Be Involved in a Code of Conduct Revision Project?In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to conduct the project? Often organizations have the expertise, vision and skills to complete a code project internally — but do they have the time? Eric addresses these common issues that come up with many, many organization’s code projects. Eric also discusses the thought process a te...2017-08-1311 minCompliance BeatDo The Sentencing Guidelines Matter Anymore?Recently we’ve seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that’s come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining “effectiveness” for a compliance program. Eric addresses these recent questions head-on. The Sentencing Guidelines have staying power — going back to 1991. And they still underpin most, if not all, of the standards and guidance we see not only from the Department of Justice in the USA, but also i...2017-07-2213 minCompliance BeatTips for Compliance and Ethics Program IncentivesSince incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations can do to consider incentives and talks about different ways that organizations have addressed incentives in the past and what probably has worked and what may not be so effective. Eric provides some advice on ways to approach the incentive issues and discuss th...2017-07-1612 minCompliance BeatKeeping Compliance Front of MindThis time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage in outreach. We also provide some practical examples of engagement activities to try and get the stakeholders to be more involved with the program through competitions and other activities. Eric talks about how getting people involved can be very powerful for both them and your program. Eric also encourages compliance programs to be creative and try something...2017-07-0110 minCompliance BeatThree More Ways to Involve Managers in Compliance and EthicsIn this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of the organization. One way to better involve the middle is to make sure managers are armed with the knowledge and resources to be a successful conduit for the program. Eric provides some practical ideas on how, and with what, to arm the managers. Eric talks also about involving the managers in specific initiatives or projects and provides some specific examples of...2017-06-2517 minCompliance BeatCompliance Communication FailuresWhat are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training, compliance officers have occasionally struggled with how frequently and in what ways to address compliance communication. In this episode, Eric talks about some common issues organizations have faced when considering the more informal side of efforts to educate and inform employees and other stakeholders about compliance risks and issues. Eric also focuses on ways organizations can address these common situations and how the recent the Department of Justice’s...2017-06-1011 minCompliance BeatDOJ’s New Guidance & Interactive Code of Conduct & Part Two of Our Interview with Alison TaylorThe new Department of Justice‘s guidance, the Evaluation of Corporate Compliance Programs, discusses the “design and accessibility” of written standards, such as your code of conduct. Does this focus on “design” in particular mean that organizations should reconsider or review the use of interactivity for their code? What does the Department’s focus on “communication” and “evaluation” of written standards affect how an organizations evaluates and implements any interactive features? Eric discusses what the new focus on design and accessibility might mean and how organizations can address these expectations in their code of conduct review, revision and development processes.
Eric...2017-05-1436 minCompliance BeatThe New DOJ Guidance on Code of Conduct & Part One of a Special Interview with Alison TaylorHow does the new Department of Justice’s new guidance, the Evaluation of Corporate Compliance Programs, from February 2017 approach the requirements for written standards, including code of conduct? Eric walks through three key takeaways from the Evaluation of Corporate Compliance Programs on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR on her new white paper, The Five Levels of Organizational Culture.
While neither the new guidance, nor the Sentencing Guidelines that proceeded it by 25 years, speak...2017-05-0526 minCompliance BeatTeaching Moments: What Can We Learn About Compliance Failures From Baylor University?As an alumni of Baylor University, Eric has closely followed the allegations that Baylor University violated its obligations under Title IX. Six months after his first episode looking at this issue, Baylor University, unfortunately, is still in the news. What’s going on? What lessons can compliance professionals learn from Baylor University and how this compliance failure has been handled?
Baylor University’s Board of Regents have provided a playbook of what not to do when responding to a compliance failure. When looking at how Baylor has handled this situation, Eric considers three key teaching moments. First, Baylor’s...2017-04-2916 minCompliance BeatThe Relationship Between Culture and Compliance & Special Interview with Laura CordovaWhat’s the difference between compliance and corporate culture? Is there a difference? How do they work together? In this episode, Eric looks at how two airlines, United and Delta, responded recently to challenges they faced and how their responses speak to their corporate cultures. Both airlines faced operational failures. The juxtaposition of their responses are excellent teaching moments and examples that compliance professionals can give to demonstrate the relationship between compliance and corporate culture.
United has a bad week. Much attention has been focused on the gentleman who was recently physically and forcefully removed from a pl...2017-04-1932 minCompliance BeatHot Topics in Compliance & Ethics in Europe Part IIAs Eric returns from the Society for Corporate Compliance & Ethics European Ethics & Compliance Institute in Prague, he shares the hot topics of discussion at the conference. He discusses his three main takeaways from the conference.
First, there is strong interest in corporate culture in Europe. Focus on ethical culture and compliance can vary between countries and cultures. In the past, many have held the belief that emphasis on compliance programs is not as strong in Europe as it is the US. But that’s not a fair assumption. There is a strong recognition that healthy corporate cultur...2017-04-1211 minCompliance BeatThe Board of Directors’ Relationship with Your Compliance Officer & the Evaluation of Corporate Compliance Programs & Three Questions with Jean-Marc LevyWhat does the Department of Justice Fraud Section’s new Evaluation of Corporate Compliance Programs say about your compliance officer’s relationship with your Board of Directors? There are three salient points that you can take away from the Evaluation of Corporate Compliance Programs with regard to the Board of Directors. Some of these points aren’t necessarily new concepts, but they certainly give us more guidance in terms of what the Department of Justice is looking for when considering this relationship. In this episode, Eric takes a deep dive into the Evaluation of Corporate Compliance and how it relates...2017-03-2224 minCompliance BeatThe Checklist That’s Not A Checklist Part 3: What does the new guidance from the DOJ Fraud Section mean?The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the “checklist” expands on it. If it’s not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.
In this first of what has tu...2017-03-1517 minCompliance BeatThe Checklist That’s Not A Checklist Part 2: What does the new guidance from DOJ Fraud Section mean?The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but the DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the “checklist” expands on it. If it’s not a checklist, what does it all mean? How can it help you? Eric examines each of the Sample Topics and Questions that the DOJ puts forth in this new guidance.
In this first of what has tu...2017-03-0917 minCompliance BeatThe Checklist That’s Not A Checklist Part 1: What does the new guidance from the DOJ Fraud Section mean?The Department of Justice Fraud Division released the Evaluation of Corporate Compliance Programs in middle of February without any announcement or fanfare. Is it a checklist? It looks like a checklist, but DOJ says it’s not a checklist or formula. Some of the information in the Evaluation you’ve heard before, but the “checklist” expands on it. If it’s not a checklist, what does it all mean? How can it help you?
In this first of a two part series, Eric discusses in depth five of the eleven topics covered in the Evaluation as well as their s...2017-03-0218 minCompliance BeatWhen and how will the organizational sentencing guidelines be amended? & Three Questions with Joe MurphyThis is another episode in our ongoing series: Sentencing Commission Confidential. The United States Sentencing Commission is the steward of the organizational sentencing guidelines. It’s helpful to understand how the United States Sentencing Commission decides to amend certain guidelines before we answer this episode’s questions. Eric explains how the Sentencing Commission sets its amendment priorities, the comment process and how to participate in it, and the actual amendment process. The Sentencing Commission could amend the organizational sentencing guidelines every year, but these guidelines have been very infrequently amended. In the past, organizational guideline amendments have been very evolu...2017-02-2235 minCompliance BeatBusting Three Third-Party Myths & Three Questions with Eric FeldmanEric often encounters three myths that organizations believe when considering the liability they may face because of third-party partners’ or agents’ conduct. In this episode, Eric explains why believing these myths creates liability risks for your company.
Myth No. 1: Many people believe that third-party compliance is only anti-corruption, anti-bribery, and/or potential Federal Corrupt Practices Act (FCPA) violations. Your risks, however, are much broader than just those three risk areas. Eric explains why you should be concerned about your third-party agents’ or partners’ compliance in many other risk areas.
Myth No. 2: Many organizations believe that if they are o...2017-02-1539 minCompliance BeatShould you have a third-party vendor or partner code of conduct? & Three Questions with Kelly ClarkAccording to benchmarking data, less than half of organizations currently have third-party codes. There’s a current trend of partners asking each other to “sign off” or certify to codes of conduct. You must first assess your risk before answering whether you need a third-party code. Other controls you already have in place, such as contracting language, may fill the need. Third-party codes should be purpose made and they often cover far less information than employee codes of conduct. In this episode, Eric answers:
Why would your organization need a third-party code?Tweet This
What do these documents look like?
What type...2017-02-1028 minCompliance BeatCompliance Officer Liability after VW & TakataWhat does the flurry of indictments against individuals at Volkswagen and Takata tell us about compliance officer liability after the Yates Memo? Eric revisits the impact of the Yates Memo on compliance officer liability with the news of these prosecutions. The Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, DAG Yates lays out new guidance to Department of Justice attorneys who are prosecuting individuals involved in corporate wrongdoing. An earlier episode, “Does the Yates Memo increase my liability as a compliance officer?”, examines data collected by th...2017-02-0116 minCompliance BeatWhat are three ways to involve managers in your compliance & ethics program? & Three Questions with Gretchen WintersHow do you create tone from the middle?Tweet This Middle managers are some of the most important members of your compliance and ethics team. Research shows that employees are more likely to report concerns about misconduct to their direct manager or supervisor rather than use a hotline. Eric discusses this data more specifically in “What can you do to prevent retaliation and encourage employees to report retaliation?” and “Why does no one call the helpline?”. Giving managers the resources to be effective leaders and engaging managers in your compliance and ethics program is one of the best ways to prevent c...2017-01-2513 minCompliance BeatWhat can you do to prevent retaliation & encourage employees to report misconduct? & Three Questions with Che HembreyIn order to answer this question, it’s important to first look at the data on retaliation. In three different reports, two in 2012 and one in 2015, the Ethics and Compliance Initiative examined the percentage of employees that report witnessing misconduct. These reports found that 40% to 50%, or approximately four out of ten employees, witnessed misconduct. The percentage of employees that then report misconduct is around 60%. Of the employees that report, 21% employees, or about one out of five, reported experiencing retaliation after reporting. These reports also found that retaliation spikes with organizational change.
In order to prevent retaliation, we ha...2017-01-1823 minCompliance Beat2017 Trends in Compliance & Ethics Special EditionWhat are going to be the overarching trends in compliance and ethics in 2017? Tweet This In this episode, Eric talks about compliance and ethics program trends that will affect every company, no matter your size and no matter whether you are in a highly regulated space.
First, in the past year there has been lots of discussion deregulation. Will potential deregulation lessen the importance of compliance? How can you make the case for continued focus on compliance? How can you keep up the conversation within you organization? As part of his discussion, Eric references the data in the...2017-01-1116 minCompliance BeatShould you use interactive design for your code of conduct? & Three Questions with Ricardo Pellafone
When you are updating, refreshing, or rewriting your code of conduct, you should consider whether or not to create an interactive code of conduct. An interactive code of conduct is a digital document that a reader truly connects with. This document, which may be an interactive PDF (Adobe Portable Document Format), has clickable functions, such as learning aids, comprehension aids, videos, and/or links to other policies or documents. These elements allow readers to interact with the document as they read through it. A learning aid may ask a question, allow the reader to select an answer, and then tel...2017-01-0437 minCompliance BeatDo we need to train our Board of Directors on compliance and ethics? & Three Questions with JoAnn MahoneyThe short answer is yes, you must train your governing authority, which may be your Board of Directors, on your compliance and ethics program. The U.S. Sentencing Guidelines require that you do so because the Board is required to oversee your program. How does this look in practical terms? Eric discusses what he calls the three pillars of Board of Directors’ training:
Compliance Risk Topic Specific Training. These topics may include conflicts of interest, anti-corruption, data protection, data privacy, insider training and other specific risk topic training.
Periodic Review/Discussion of Board of Directors’ Responsibilities. This should addre...2016-12-2833 minCompliance BeatCompliance Failures & Crisis Management: What can we learn from Baylor University & Penn State?Sexual assault allegations rocked two prestigious university football programs, Penn State and Baylor University. Both universities took two different paths to addressing the underlying compliance, governance and risk problems that led to the scandals. Penn State embraced a transparent approach to addressing the problems. In contrast, Baylor’s Board of Regents have blocked stakeholders’ efforts to understand the root causes of their compliance failures.
In fall of 2011, Jerry Sandusky, a former assistant football coach for the Penn State Nitany Lions, was charged and convicted of multiple counts of sexual abuse of children. Several Penn State University officials, whose alle...2016-12-2416 minCompliance BeatDoes the Yates Memo increase my liability as a compliance officer? & Three Questions with Ted BanksThe Yates Memo, written by Deputy Attorney General Sally Yates and released on September 9, 2015, addresses individual liability for corporate wrongdoing. In the memo, the DAG Yates lays out new guidance to Department of Justice attorneys who are prosecuting individuals involved in corporate wrongdoing. When you review the data over the years preceding the Yates Memo, the data shows that the DOJ does a pretty good job of prosecuting individuals involved in corporate wrongdoing. From data collected by the United States Sentencing Commission, we know that in just about 60% of cases where an organization is charged with criminal conduct, an...2016-12-1630 minCompliance Beat“What are the dos and don’ts of written compliance policies?” & Three Questions with Wesley BizzellWritten standalone policies, along with your code of conduct, form the foundation of an effective compliance and ethics program. Often organizations focus on rewriting and redesigning code of conduct to meet current best practices and do not consider rewriting standalone policies, even though most codes of conduct reference these other policies. It is important to note that the Sentencing Guidelines don’t mention code of conduct specifically, but the Guidelines do require that an organization establish standards and procedures to prevent and detect criminal conduct. When you are updating your code of conduct, you should also be considering the polici...2016-12-0726 minCompliance Beat“What are the key steps for effective assessment interviews?” & Three Questions with Kathleen GrilliAs your organization approaches a regular assessment of your compliance and ethics program, consider whether you need to include personnel interviews as part of the process. Many organizations rely solely on benchmarking data and surveys to assess their programs. Time constraints can often prevent a deeper dive into program effectiveness. While not every regular assessment may need to include interviews, interviewing personnel from across the organization can provide helpful insights. Interviews can uncover issues that you simply cannot discover when relying solely on the data. During the interview process of an assessment, many organizations regularly talk to the usual sus...2016-11-3024 minCompliance Beat“What can we learn about corporate culture from Wells Fargo?” & Creating an Ethical Culture: A Conversation with Robert G. Jones of Old National BankThe Wells Fargo fraud allegations show that there can be a tremendous disconnect between the C-Suite’s perception of an organization’s ethical culture and the actual culture in the local workplace. Former Wells Fargo CEO John Strumpf testified before Congress that he firmly believed that executives had created an ethical culture at the bank. Where did Wells Fargo go wrong? “Tone from the top” is an often used phrase in the compliance and ethics space. But as the Wells Fargo allegations show us, tone from the top isn’t always enough to ensure that employees on the ground act ethically...2016-11-2321 minCompliance Beat“Should we translate our Code of Conduct?” & Three Questions with Ronnie FeldmanWhen considering whether to translate your Code of Conduct into other languages, there are some surprising nuances. If your organization typically translates documents, you may be familiar with the basic process. Translating a Code of Conduct, however, is a little different than other documents because there are more factors to consider. Among them, you need to consider the process of translating the layout and design as well as text and who your audience is in each country in which you have operations.
What factors do you need to consider when determining whether to translate and, if so, which la...2016-11-1621 minCompliance BeatDo the Sentencing Guidelines require an independent chief compliance officer? & Three Questions with Jennifer BadgleyThe US Sentencing Guidelines require that individuals within an organization be delegated with day-to-day operational responsibility for the compliance program. When defining the role of this individual, the Guidelines say that the person with day-to-day operational authority shall report to high level personnel, and when appropriate, the governing authority of the organization on the effectiveness of the program. In addition, the Guidelines require that the individual responsible for the compliance program have adequate resources, appropriate authority, and direct access to the governing authority. Does this mean that the chief compliance officer or the employee tasked with day-to-day operation of th...2016-11-1022 minCompliance BeatHow can the Sentencing Commission data help you make the case for the importance of a compliance and ethics program? & Three Questions with Amy LillyThe United States Sentencing Commission is charged with collecting a vast amount of data regarding the sentencing of criminal defendants in federal courts. Among this data is a surprising amount of information regarding the organizations that take convictions in federal court for compliance and ethics failures. Many times, compliance and ethics professionals rely solely on current news to garner what information on compliance and ethics failures. The news, however, only covers a small fraction of the organizations that are charged with federal crimes. The data from the Sentencing Commission tells us the full story—a story that has more su...2016-11-0322 minCompliance BeatWhat do the Sentencing Guidelines say about training? & Three Questions with David SearleTraining is one area where the Sentencing Guidelines give us specific information about what’s expected for an effective program. Is your training program clear? Does it effectively communicate the company standards? Is everyone meeting these standards?
Another important effective training issue is coverage. Who is receiving it? Does it include remote employees? Does it include management, the board of directors, etc.?
The Guidelines specify “periodic” training but does not define this term. What does it mean?
How can an organization test to find out if it’s training is practical? One way is to select a...2016-10-2822 minCompliance Beat“Do we need to invest in an anti-corruption program?” & Three Questions with Douglas VeiviaShould we be investing in an anti-corruption program?
Anti-corruption risk is a “high severity/low likelihood” risk for nearly all organizations. But, if it does happen it can be very serious. Eric will look at data between the Department of Justice and various corporate defendants.
If you are asking, “Should we be investing in an anti-corruption program?” it’s probably not the question you should be asking. There are more important questions– “What are the compliance risks for this organization?” “Have you done a compliance risk assessment? “Have you evaluated what risks you face as an organizatio...2016-10-2513 minCompliance Beat“Should you market the ethics & compliance culture of your organization?” & Three Questions with Erica Salmon ByrneThere are both potential positives and negatives when you market or publicly announce your particular commitment to compliance and ethics. Or as more organizations are doing in recent years, seeking to certify that their program meets certain standards.
Let’s focus on a couple of the potential downsides or negatives. When you market your program as being a “best practices” program you need to expect that external forces and maybe even some internal forces will want to investigate. Be prepared to support and show that the program does indeed meet the standards. This may seem obvious, but beyond th...2016-10-2116 minCompliance Beat“Why is the United States Sentencing Commission involved in compliance and ethics?” & Three Questions with Tom Fox
This is part of a continuing series called Sentencing Commission Confidential. Let’s take a look at the history and operation of the sentencing guidelines and in particular chapter 8 of the sentencing guidelines that have to do with organizations. Let’s go back in time to 1984, this was before the United States Sentencing Commission. In 1984, there was a bipartisan movement in Congress to reform overall federal sentencing practices. If you remember the 80’s, you might remember parachute pants, Michael Jacksons’ “Thriller” and let’s not forget Ivan Boesky and Michael Milken, junk bond kings—insider traders. We are all too famili...2016-10-1712 minCompliance Beat“What does a foundation mean?” & Three Questions with Nicole TarasoffThe Code of Conduct is the Foundation
Why does the Department of Justice and the SEC call the Code of Conduct the foundation of an effective compliance and ethics program? This question is something that has come up often over the last few years and this terminology— the foundation has become a buzzword. Let’s take a step back and look at where the Code of Conduct became such a vitally important piece of the puzzle for a compliance program. If we look back at the original U.S. Sentencing Guidelines standards for organizations, which by the way a...2016-10-1216 minCompliance BeatSCCE Conference Highlights-Special EditionThe SCCE Compliance and Ethics Institute Conference in Chicago on September 24-27, 2016 is the stage for this podcast.
Eric Morehead, host of Compliance Beat was in attendance at the SCCE conference, along with 1700 compliance professionals and shares conference highlights and emerging trends in this Special Edition. The profession continues to grow and expand and more importantly people want to continue to grow and learn as they find themselves responsible for compliance issues.
Trends
A surprising & interesting trend is to now find newly appointed compliance officers or professionals wearing multiple hats. It’s fair to say...2016-10-0612 minCompliance Beat“Does the DOJ require an independent compliance officer?” & Three Questions with Bill BrownThe USDOJ has required an independent compliance function in some recent corporate settlements, but is this the official position of the Department? We discuss the the intersection of these recent developments, the US Federal Sentencing Guidelines and how this might relate to whether your compliance officer has the necessary independence to craft and maintain a compliance program that is effective. Just what are the expectations from the Department and can we ensure that that our compliance function will meet those standards? In this episode, Eric answers these questions and discusses just what independence a compliance officer must have to...2016-09-3013 minCompliance BeatIntroductory EpisodeIn this introductory episode, get to to know Eric Morehead, Host for Compliance Beat podcast. Eric talks about the goals for the show. He tells you a little about himself and his compliance and ethics journey. We are excited about this show and invite you to join us in this journey. Please be sure to subscribe.
2016-09-1503 min