“Fraud is not an accounting problem; it is a social phenomenon.” Joe Wells
Investigation Roundtable on January 23, 2019, in Center City Philadelphia
On December 6, 2018, in New York City, the Securities & Exchange Commission (“SEC”) Chair Jay Clayton delivered his speech, where he outlined where the
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.