Insider trading and “inner controls”

Here is my latest column in Compliance & Ethics Professional – which looks at insider trading from a behavioral compliance perspective. I hope you find it interesting.

Conflicts of interest in a post-Trump era

In a classic Watergate-era Doonesbury, Mark asks rhetorically whether it is fair to judge the ethicality of the White House based solely on the various cases and allegations that had surfaced during that scandal. No it isn’t, he replied: those are only the ones we know about. The latest Trump […]

Answers to tough questions on conflicts of interest

Recently our friends at NAVEX Global invited Rebecca Walker and me to teach a master class on conflicts of interest. Part of the session involved our receiving and responding to key questions about COIs. We thought you might like to see this Q & A.    

Approvals of conflicts of interest: what is the appropriate standard?

  While some organizations bar conflicts of interest in all cases, many opt for allowing COIs  to exist where appropriate. But how should appropriate be defined for these purposes? One formulation that I have recommended is: A COI may be approved only where doing so would clearly be in the […]

PLI briefing on revised DOJ compliance program standards

Rebecca Walker and I hope to see you then and there. 

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.