Archive for 2020

Are you a member of the “compliance elite”?

In “Compliance Elites ”Professor Miriam Baer of Brooklyn  Law School writes: “As corporate compliance has expanded its influence, so too has the status of those who implement and oversee the firm’s compliance function. Chief compliance officers (CCOs), who are often (but not exclusively) lawyers by training, increasingly boast the types of […]

Nearly 1500 C&E professionals have downloaded the free risk assessment e-book

Have you? It is available from Corporate Compliance Insights. I hope you find it useful.

Making the most of risk assessment

Today the FCPA Blog published a post I authored on risk assessment. I hope you find it useful.

Moral hazard and the revised DOJ compliance standards

One of the great afflictions of our age is moral hazard. As noted in an earlier post: “The concept of moral hazard was used originally to refer to the phenomenon that providing insurance tended to promote risky behavior by insured parties.  Subsequently, the idea has been applied more generally to mean […]

Revised DOJ compliance program standards: what is new

In the most recent posting on the Compliance Program Assessment Blog Rebecca Walker and discuss what is new in the  June 1, 2020  update  to the Department of Justice’s standards for evaluating compliance programs. We hope you find it useful.

Assessing conflict of interest compliance programs

Here is a just-published article in Corporate Compliance Insights by Rebecca Walker and me on conducting assessments of conflict of interest compliance programs. We hope you find it useful.

Beyond the attorney-client privilege

In my latest column in Compliance & Ethics Professional I consider the issue of whether program assessments should be conducted under the attorney-client privilege. I hope you find it useful.  

Mapping the field of “”behavioral business ethics”

In “Toward a Better Understanding of Behavioral Ethics in the Workplace,”  David De Cremer of the Business School, National University of Singapore, and Celia Moore of the Cambridge Judge Business School, review literature that is part of the growing area that they call “behavioral business ethics.” They use this formulation […]

More on “reverse conflicts of interest”

In a post several years back I discussed what could be called “reverse conflicts of interest,” starting with an example from my work: A company enters into a complex business arrangement where one of its managers has a relationship with the other entity.  The relationship is fully disclosed and approved […]

Assessing conflicts of interest risks

Conflicts of interest have long been seen as an area of significant risk. But that does not always translate into the conduct of meaningful risk assessments. Part of the reason for this disconnect is a widespread belief that COI risks are already well known. Certainly every C&E professional knows that […]