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Outsourcing Compliance and the CCO

One of the requirements of registration as a registered investment adviser is the appointment of a Chief Compliance Officer and the establishment of a formal compliance program. The SEC stated that a firm need not hire a new person to be the CCO. However, there will be a substantial time commitment...

Jeannette Rankin, Infosys, Ethics and Compliance

Who was Jeannette Rankin and why do we celebrate her today in the context of ethics and compliance? She was the first female to be elected to Congress, as a Representative from Montana in the 1916 elections. In 1917 she was one of 50 votes opposing America's entrance into World War I. She had...

New Compliance Surveys: “The Answers Are Not Pretty.”

While there is no shortage of compliance and ethics polls/surveys which populate the newsfeeds, there are two that recently caught my attention, both of which point to the same result, as well stated in The Street, The Bull and The Crisis (published by The University of Notre Dame and Labaton Sucharow...

Great Structures Week III – The Roman Arch and Resourcing Your Compliance Program

I continue my Great Structures Week with focus on structural engineering innovations from ancient Rome. I am drawing these posts from The Teaching Company course, entitled “ Understanding the World’s Greatest Structures: Science and Innovation from Antiquity to Modernity ”, taught by...

The New Canadian Integrity Regime: Compliance Carrots to Join the Sticks

Today we welcome Kristine Robidoux, Partner, Gowling Lafleur Henderson LLP, for an analysis of the new Canadian Integrity Regime. As Canada has one of the most robust Debarment regimes which includes anti-bribery enforcement, I thought that a change in the Regime was worthy of additional focus. Thus...

What Message Is Being Sent to CCOs by SEC Commissioners?

The role of the chief compliance officer is the talk of the Securities and Exchange Commission these days – or at least some of its Commissioners. Those who are speaking for the record agree that the role of the CCO is important. Those who are speaking for the record agree that the CCO should not...

Social Media Week Part IV – Telling a Story About Honey

I continue my exploration of the use of social media in doing compliance by taking a look at a very innovative social media solution to a difficult compliance issue around, of all things, honey. This example shows how creative thinking by a lawyer, in the field of import compliance, led to the development...

Social Media Week Part V – Tools and Apps for the Compliance Practitioner

To conclude this week’s posts, I wanted to list some of the more prevalent social media tools, explain what they are and how you might use them in a compliance program. (As usual I got carried away so this series will conclude on Monday of next week.) You need to remember that your compliance customer...

Social Media Week Part VI – Social Media and CCO 3.0

I conclude this exploration of the uses of social media in doing compliance by exploring why the compliance function is uniquely suited to using social media tools. Long gone are the days when Chief Compliance Officers (CCO) or compliance practitioners were lawyers housed in the Legal Department or the...

Hiring in Compliance – Part I: Developing the Job Profile and Criteria

A couple of weeks ago, I had a guest post from Maurice Gilbert, the Managing Partner at Conselium Partners LP entitled “ Why is it so hard to hire compliance practitioners? ” There were many questions posed to me based upon Gilbert’s guest post. This led me to propose to Gilbert a series...