Welcome to my site. I have spoken and been the keynote speaker for many conferences, including the ABA, ACC, ACFE, IIA, and IMA to name a few. I have designed customized training for the board, senior leadership, legal, compliance, internal audit, and others for some of the world’s largest organizations.
Corruption can take many forms, but its root cause could and often does include a conflict of interest of some sort and possibly collusion. OECD states, Conflict of interest occurs » Read More
At a minimum, as part of (emphasis added) your overall fraud risk management program, the following key processes/functions should be analyzed along with the embedded (key) internal controls, if » Read More
While we can’t get into the mind of the white collar criminal, we can take a closer look at high-profile individuals who have perpetrated massive fraud at corporations and instances of fraud identified in practice, as well as some research, to help is identify a pattern of similar behavioral elements common to white-collar crooks and cultural elements common to their environments.
I often ask board members, senior leaders, chief audit executives, and others about the maturity of their Enterprise Risk Management (ERM) program and I get odd responses. The oddest response » Read More
July 2018 Last week I was speaking at an ethics and compliance event in Houston, where one of the other speakers stumped the crowd with a deceptively simple question: What » Read More
Lack of separation of the CHIEF COMPLIANCE OFFICER (CCO) and the GENERAL COUNSEL (GC) has been cited as a cause of numerous corporate mishaps or failures. In fact, separation is now the norm in Health Care organizations. In spite of numerous recommendations to separate the two functions, there is general agreement that the roles are closely related, and frequent collaboration is required.