Articles | Compliance Week – Page 293
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When Enterprise Legal Management and GRC Collide
Software vendors offer a range of products known as “enterprise legal management” to help the legal department analyze spending, discern patterns, and manage costs. Given that many legal costs are the result of some governance or compliance risk, is there an opportunity to use enterprise legal data to improve your ...
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Practical Ideas on Managing Reputation Risk
Image: Reputation risk is the strategic business issue for many boards and senior executives today, and yet few know how to address it well. “Reputation is an ‘amplifier risk,’ because it attaches itself to other risks,” says Andrea Bonime-Blanc, head of consulting firm GEC Risk Advisory. She and others recommend ...
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An Insider Look at the EU’s Binding Corporate Rules
Companies that move data throughout Europe, or beyond its borders, face a long and exacting list of privacy and security demands. Some companies are choosing to take advantage of Binding Corporate Rules (BCRs), presenting their data compliance framework for approval by data protection authorities. BCRs, despite a lengthy approval process, ...
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Where Internal Audit Can Help in Cyber-Security
Image: With yet another huge data breach hitting Corporate America—add insurance giant Anthem to the Hall of Shame—internal audit departments are trying to pinpoint what expertise they can bring to the company’s cyber-security risk assessment. Plenty, many audit executives say. “There are technical aspects of these projects, but regardless of ...
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CW 2015 Conference Preview: Assessing Program Effectiveness
Image: Compliance officers are under constant pressure to demonstrate to senior executives, their boards, and regulators that the compliance function works. That means finding ways to measure compliance program effectiveness. To develop those metrics properly, “you have to define your goals,” says Anne Harris, former chief ethics officer of General ...
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‘Broken Windows’ Strategy Raises Risk-Management Fears
The SEC has been pushing its “broken windows” enforcement strategy for more than a year now, chasing down minor infractions alongside larger securities violations. What have we learned? For starters, don’t expect isolated citations; larger sweeps get more bang for the SEC’s buck. As for compliance officers, their jobs will ...
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Dueling Thresholds Emerge on Going-Concern Warnings
Image: A new accounting standard meant to give investors more warning of when a company is in trouble could actually lead to less warning of trouble. Audit and accounting professionals are struggling over conflicting interpretations of “substantial doubt,” and the answer is not easy. “I’m not sure if the standard ...
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When Revenue Recognition and Executive Pay Collide
Image: The impending new accounting standard for revenue recognition already has corporate accountants buzzing; now compensation committees should brace for impact. The standard redefines a host of terms under the heading of “revenue,” and that will affect pay plans. “To the extent executive compensation is triggered by company performance … ...
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ABA Seeks Clarity for Corporate Monitors
Image: The American Bar Association is mulling new standards for corporate monitors that effectively could make the monitorship process a lot easier, cheaper, and transparent for compliance officers working with them. “The standards go a long way toward facilitating a better relationship between the monitor and the company,” says John ...
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How to Respond to a China Antitrust Probe
Chinese regulators are stepping up enforcement of antitrust laws, resulting in more investigations of U.S. companies. “Foreign companies doing business in China need to know that Chinese antitrust authorities have far-reaching enforcement powers, and that the procedural safeguards are not the same as those which may apply in the United ...
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What Critics Say on Three Lines of Defense
The Three Lines of Defense model for risk oversight—business units in the first line, compliance in the second, internal auditors in the third—has been hugely popular in recent years. Proponents love it, and regulators have come to expect it. Critics, however, say the Three Lines model is too simplistic a ...
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Paths to Globalizing Your Code of Conduct
Image: A thoughtful and well-drafted Code of Conduct is the cornerstone of any strong corporate compliance program. Making that cornerstone strong enough to support a compliance program worldwide, spanning all manner of cultures—that’s the tricky part. “We’re constantly trying to figure out better ways to deliver our message while keeping ...
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When State Attorneys General Come Knocking
Sometimes a sheriff arrives from the federal government to take an enforcement action against your company, and sometimes a posse of state attorneys general follow behind, determined to investigate you too. Such is the case for JP Morgan, now being pressed by 19 states for more detail on its massive ...
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Why Boilerplate Battles Continue to Rage
Image: Again and again, with both guidance and comment letters, the SEC has urged companies to avoid using “boilerplate” language in disclosures—and companies never seem to embrace the message. “There is an extraordinary amount of boilerplate disclosure across topics and across industries,” says Jean Rogers, head of the Sustainability Accounting ...
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The Slog Begins for New Revenue Standard
Image: FASB’s effort to implement its new standard for revenue recognition by 2017 is bumping against business reality, as different parts of Corporate America grow vocal about their ability—or lack thereof—to manage the task. “A lot of companies are trying to correlate the messaging around a potential deferral and potential ...
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SEC, FINRA Dropping Hints on Risk
Compliance officers looking to read some tea leaves about what worries the Securities and Exchange Commission these days might want to skim the 2015 exam priorities that the SEC and FINRA have posted. That guidance applies foremost to financial firms, but “it’s only a matter of time before they require ...
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CW 2015 Preview: Assessing Antitrust Risks
Image: Enforcement of antitrust law is rising around the world, particularly in some of the most desirable markets for overseas expansion, including China, India, Brazil, and Mexico. Inside, we have an overview of how to assess your antitrust risks—which can be quite different from one country (or one product line) ...
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What a Good FCPA Audit Looks Like
Image: An audit of compliance with your company’s FCPA policies is no easy task. It requires skilled personnel, sophisticated data analytics, and an understanding of the difference between an audit and investigation. Inside, we walk through the fundamentals of all three. “The focus is really to create dialogue” with audit ...
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Planning Ahead to Manage M&A Due Diligence
Image: Lots of mergers look great on paper. In the real world, however, integrating corporate IT systems can not only be a headache for the IT department; core business functions can be compromised—including financial reporting or other tasks crucial to effective corporate compliance. “Smart companies are ready to start integrating ...
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Balancing Best Practices and Reality in Compliance
Everyone likes best practices in compliance, and everyone knows the U.S. Sentencing Guidelines are the cornerstone of an effective compliance program. The truth is not quite so perfect: Best practices can be impractical, and not all guidance about the Guidelines is clear. This week, guest columnist Susan Divers, a former ...