Archive for 2019

Summer compliance reading for boards of directors

A recent post by attorneys at the Sullivan & Cromwell law firm on the blog of the Harvard Law School Forum on Corporate Governance and Financial Regulation examined an important decision issued last month by the Delaware Supreme Court which “reversed the dismissal of a stockholder derivative lawsuit against the […]

Lawyers as compliance officers: a behavioral ethics perspective

What role do corporate lawyers play in preventing wrongdoing by executives in their client organizations? And how is this role impacted by behavioral ethics? In “Behavioral Legal Ethics Lessons for Corporate Counsel,” to be published in the Case Western Reserve Law Review, Paula Schaefer of the University of Tennessee College of […]

Ethics made easy

We justly praise those who show true ethical heroism.  But to protect business organizations  and society generally from legal and ethical breaches we need to aim our efforts more broadly. In “How to Design an Ethical Organization” in the May-June 2019 issue of the Harvard Business Review, Nicholas Epley, John […]

Trump’s hotel

As noted in the Washington Post last month: President Trump recently released financial disclosure forms which “show that the Trump International Hotel produced $41 million in revenue, which, according to CNN, brings to more than $80 million the total amount he has made from the property during his presidency. The […]

Point-of-risk compliance

Here is my latest column from C&E Professional – on  “point-of-risk compliance.” I hope you find it useful.

The toll at the top

As recently reported by NPR: For decades, the main reason chief executives were ousted from their jobs was the firm’s financial performance. In 2018, that all changed. Misconduct and ethical lapses occurring in the #MeToo era are now the biggest driver behind a chief executive falling from the top. That’s […]

Behavioral ethics program assessments

Rebecca Walker and I have an article in the Spring 2019 issue of Ethical Boardroom on behavioral ethics program assessments. We hope you find it interesting.

E-book on compliance & ethics risk assessment

I am pleased that Corporate Compliance Insights has just published a revised and expanded edition of my e-book on risk assessment: Compliance & Ethics Risk Assessment: Concepts, Methods and New Directions. You can get a free download here.

Risk assessment expectations under DOJ C&E program evaluation criteria

A column in Corporate Compliance Insights. I hope you find it interesting.

Preventing investigative failures

It is too soon to know how history will judge the efficacy of the Mueller special counsel investigation. But there is no shortage of clear investigative failures in the private sector, such as in the Wells Fargo debacle. In Complex Compliance Investigations – a soon-to-be-published article in the Columbia Law […]