My notes, live, from the keynote address by David Ogden, the Deputy Attorney General. As we confront the current financial crisis and try to restore trust and accountability, we have a shared responsibility to make sure justice is done. Responsible corporate behavior must be encouraged and rewarded. There will continue to enforcement action on financial [...]
Structuring Internal Investigations
on June 4, 2009 in Compliance Programs
My notes, live, from the presentation by Neal Stephens and Bill Freeman of Cooley Godward Kronish on the top ten problems and how to avoid them. The focus of the session was to help companies who must conduct an internal investigation avoid pitfalls that add expense, embarrassment and exposure. There are many problems that come [...]
Third Party Risks
on June 4, 2009 in Compliance Programs
My notes, live, from Third Party Risks with Matt Tanzer of Tyco International and Chris Nowak of Wyndham Worldwide. For Tyco they have 110,000 employees around the world, most outside the United States. Their first step was to identify all of the third parties. This was a big task. They went to their master vendor [...]
McNulty Keynote on a Tale of Two Sectors
on June 4, 2009 in Compliance Programs
My notes, live, from former U.S. Deputy Attorney General Paul McNulty Keynote on A Tale of Two Sectors: The Challenges of Corporate Compliance – When Enforcement Increases and the Economy Declines. Mr. McNulty is now a partner at Baker & McKenzie. He is the author of the McNulty Memo on the government’s perspective on prosecuting [...]
The S&P Assessments
on June 4, 2009 in Compliance Programs, Conference Notes
My notes, live, from the Compliance Week Conference session by Steven Dreyer who is overseeing Standard & Poor’s program to assess corporate ERM efforts as part of credit ratings. Standard & Poor’s To Apply Enterprise Risk Analysis To Corporate Ratings (.pdf) S&P’s ERM review for non-financial companies will be based primarily on information provided by [...]
Assessing the Effectiveness of Compliance and Ethics Programs
on June 4, 2009 in Compliance Programs
My notes, live, from Jack Holleran of Ernst & Young and Patricia Prince-Taggart of CA on ways to measure program effectiveness, with an analysis of qualitative and quantitative measures. Jack put forth three primary objectives to compliance programs: To prevent non-compliance To detect non-compliance To enhance business processes and decision-making He offered the following as [...]
Harvey Pitt on Ethical Cultures in a Down Economy – Compliance Week Keynote
on June 4, 2009 in Compliance Programs, Conference Notes
My notes, live, from the Compliance Week keynote speech by Harvey Pitt on Ethical Cultures in a Down Economy: After a very brief introduction (especially compared to yesterday’s keynote) by Scott Cohen, Mr. Pitt dove into an entertaining and informative speech. Learning from history is in fact virtually impossible. The only thing we only learn [...]
The SEC’s Radical Disclosure Overhaul
on June 3, 2009 in Accounting
My notes, live, from Dr. William Lutz on The SEC’s Radical Disclosure Overhaul. (Disclaimer: The presentation represents the views of Dr. Lutz and not necessarily the views of the SEC.) He started off with a definition of “Information”: That which reduces uncertainty. (From Shannon and Weaver’s Mathematical Theory of Communication) If it’s not information, it’s [...]
It’s Not Fraud, But it Can’t be Ignored
on June 3, 2009 in Whistleblower
This session was a “dark session” so I am not sharing my notes, but will share a few themes that emerged. Most hotline complaints are for incidents that are not true compliance or ethics issues. Most studies show that HR issues tend to be almost half of the complaints. There were two camps of thoughts. [...]
Richard Ketchum Keynote from the Compliance Week Conference
on June 3, 2009 in Compliance Programs, Conference Notes
My notes, live, from the Richard Ketchum keynote at the Compliance Week Conference. Mr. Ketchum is the newly named chairman and CEO of FINRA. It is a terribly important time as financial markets are in the process of transformation. It was two years ago when the first signs of the credit crisis appeared. The silver [...]
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