Tag: Process

Speaking and Training on Fraud, Compliance, Ethics, and More…

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.

Collusion, Conflicts of Interest, and Corruption!

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

Putting the Freud in Fraud – Part Two

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.

Enterprise Risk Management – A Practical Plan

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

Compliance 101: Defining an Internal Control

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

Chief Compliance Officer v. General Counsel – Should They Be Separate?

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.

The Risk Assessment – A Recipe for Greater Success!

In addition to establishing an ethical environment, board members and management must also take the lead in implementing and maintaining a formal fraud risk management program. One key element of such a program is a fraud risk assessment.