Everything Compliance-Episode 12

 

The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords the same week the Astros are playing .700 baseball? The top four commentators in compliance return to talk about what is one their summer radar for consideration. This episode concludes with the panelists’ rants. 

1. Matt Kelly opens with a discussion of the revisions to the COSO ERM Framework, which were based on comments by practitioners. Matt considers the integration of the COSO ERM Framework into functional business units moving to operationalize ERM in organizations and we consider how the ERM Framework differs yet is complimentary to the COSO Internal Controls Framework. 

For Matt Kelly’s posts on the COSO ERM Framework, see the following:

More Details on COSO ERM Framework

Update to COSO ERM Framework Update

ERM Framework: Govt. Calls for Unity

More Clues on Draft ERM Framework

Draft ERM Framework is Here: How to Get Started 

2. Mike Volkov examines the FinCen enforcement action involving Thomas Haider, the former CCO at MoneyGram. Mike considers the implications for CCOs and whether the case even matters for CCOs. 

For Mike Volkov’s post see on the Haidar enforcement action, see the following: 

            MoneyGram CCO Pays Civil Penalty

3. Jonathan Armstrong reviews the recently released information that both Wood Group/AMEC are under the SFO concerning its Unaoil investigation. He explores some of the following questions: What should companies be doing around Unaoil? What happens if you discover a merger candidate is under investigation or in the case of AMEC, self-disclose they are under investigation. What does it mean if the acquiring entity rather than the target is under investigation? Finally, Armstrong handicaps the upcoming UK election and what it might mean for compliance. 

For Cordery Compliance's Client Alert see the following: 

        Bribery Due Diligence

4. Jay Rosen brings his Mr. Monitorship hat and former Mr. Translations eye to the question of operationalizing your compliance program. He considers how the compliance function can work with other corporate functions to embed compliance into the fabric of an organization, concluding with by doing so a compliance function could become a competitive advantage for a business. 

For Jay Rosen’s posts see the following: 

 Compliance as a Competitive Advantage

For Tom Fox’s posts on operationalization of compliance see the following: 

Operationalizing Compliance, starting with Pizza

Operationalizing Compliance by Overcoming Obstacles

Operationalizing Compliance through Human Resources

Operationalizing Compliance through the Controller’s Office

Operationalizing Compliance through Internal Audit

 

The members of the Everything Compliance panel include:

• Jay Rosen– Jay is Vice President, Business Development Corporate Monitoring at Affiliated Monitors. Rosen can be reached at [e-mail]
• Mike Volkov – One of the top FCPA commentators and practitioners around and the Chief Executive Officer of The Volkov Law Group, LLC. Volkov can be reached at [e-mail].
• Matt Kelly – Founder and CEO of Radical Compliance, is the former Editor of Compliance Week. Kelly can be reached at [e-mail]
• Jonathan Armstrong – Rounding out the panel is our UK colleague, who is an experienced lawyer with Cordery in London. Armstrong can be reached at [e-mail]