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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...

Compliance at the Tipping Point, Part I – The Yates Memo

This is the day that the US government traditionally celebrates Columbus’ discovery of the Americas, in the form of Columbus Day. My grandfather emigrated from Italy so he always took Columbus Day as his heritage day. My little sister was also born on the same calendar day, so here is to my grandfather...

Compliance at the Tipping Point, Part III – The VW Emissions-Testing Scandal

I continue my series on why I believe that compliance is at the ‘Tipping Point’ with a discussion of the Volkswagen (VW) emissions-testing scandal and its effect on the greater compliance world. Myself and many other commentators have written about the VW scandal from a variety of angles...

Compliance at the Tipping Point, Part IV – The Schrems Decision

I continue my exploration of why I believe that compliance is at the Tipping Point, with today’s entry of data point four, which is last week’s decision by the European Court of Justice (ECJ) in the Schrems case. While most commentators have focused on the Schrems decision around the lack...

Compliance at the Tipping Point, Part V – Protection Afforded From a Compliance Program

Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows , producer Val Lewton, whose films for RKO had some of the most interesting and innovative use of techniques to induce horror that have been...

Caldwell Lays It Out – DOJ Metrics for a Compliance Program

Last week Assistant Attorney General Leslie R. Caldwell spoke at the SIFMA Compliance and Legal Society New York Regional Seminar. In this speech she discussed the new Department of Justice (DOJ) Compliance Counsel. While emphatically noting that this new position was not an explicit or even tacit recognition...