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.» Read More
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
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,
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.» Read More
Many companies have an idea, albeit vague, about ERM or enterprise risk management. But few have made real progress in planning or actual implementation. What is the holdup? A practical five-step approach can help companies get their arms around ERM … and begin to realize the benefits of integrated risk management, including escalating the right risks to the right people in a timely manner, and as a result, drive meaningful conversations with leaders to inform decision-making.» Read More
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
Lack of separation of the CHIEF COMPLIANCE OFFICER and the GENERAL COUNSEL has been cited as a cause of numerous corporate 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 issues relating to separation of the CHIEF COMPLIANCE OFFICER and the GENERAL COUNSEL are most often discussed in terms of the differences in their roles (below).» Read More
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.
Risk assessments are part of the discipline of risk management, where enhanced frameworks and techniques have emerged. Risk management comprises the identification, assessment, and prioritization of risks followed by the coordinated and efficient use of resources to monitor, minimize, and otherwise control the impact of the risks on the organization.