What is the biggest reason companies miss the chance at a DOJ declination? It is almost never a decision not to disclose, and it is rarely ignorance of the law. The most common reason a company loses the chance at a declination is internal speed: the report surfaces somewhere in the organization and then [...]
Is the FCPA Still Being Enforced in 2026? What It Means for Training Is the FCPA still being enforced in 2026? Yes. Enforcement of the Foreign Corrupt Practices Act was paused by executive order in February 2025, then resumed in June 2025 under new Department of Justice guidelines that narrowed its focus toward cases [...]
Reorganize, or Make Better Decisions? The Variable Most Cross-Functional Failures Miss By Todd Corbett, Xcelus When something goes wrong across departments — a data breach that also involved employee misconduct, a harassment complaint that also created exposure to retaliation — the instinct at the top is almost always the same. Redraw the org chart. [...]
Xcelus Blog — Compliance Leadership Cybersecurity Runs Tabletop Exercises. Why Doesn't Compliance? By the Xcelus Editorial Team Editor's Note The opening scenario below is the basis for one of our Executive Decision Lab™ kits, The Invisible Insider — a 90-minute facilitated session designed for public company leadership teams who want to practice these conversations [...]
What Four Senior Leaders Wish Every Employee Knew (And Why Training Rarely Tells Them) Here's a thought experiment I've been sitting with lately. Ask a Chief Compliance Officer, an HR leader, a VP of Security Awareness, and a VP of AI Readiness the same question—what do you wish every employee actually knew?—and you'll get [...]
Is Your Compliance Training Program Designed for an Audit — or for Behavior Change? The Real Test of Compliance Training An employee is under pressure to close a deal before the quarter's end.A vendor relationship feels routine, but something is slightly off.The rules were covered in training. But in that moment, the question isn’t:“Do [...]
Where Is My Company’s Code of Conduct? Why the Better Question Is Whether Employees Need to Find It Most employees don’t know where their company’s Code of Conduct is. That’s not just a usability issue. It’s a signal that the compliance program may not be designed for the moments when employees actually need it. [...]
One Code of Conduct, Two Training Programs: Why Field Employees Need Different Scenarios Than Office Employees Every organization with a Code of Conduct wants the same thing: employees who recognize compliance risks and know what to do when they encounter one. The Code of Conduct applies to everyone. The training that makes it effective [...]
Conflict of Interest vs. Protecting Confidential Information: What's the Difference? Compliance officers frequently encounter this question — often from employees who are genuinely confused rather than trying to avoid accountability. The two topics appear on the same training list, are covered in the same Code of Conduct, and both involve situations in which personal [...]
Why Code of Conduct Training Fails to Change Behavior — And What Actually Works Most organizations have Code of Conduct training. Most employees complete it. And most compliance officers know — often with uncomfortable certainty — that completing the training is not the same as understanding it, and understanding it is not the same [...]
