Category Archives: Government

Managing information

What does it say when you try too hard to “manage” the information that gets out?  Do you have the necessary “control” of that information?  When you try to “control” it, what does it say about you when the information gets out anyway?

This sounds like “the risk of selectively releasing information.”

“Turkey Slams Saudis Over Lack of Clarity About Slain Journalist’s Body,” The Wall Street Journal, November 1, 2018 A9.  Changing stories on the death of Jamal Khashoggi.

Apparently, there are international norms on what you need to say and how you need to say it, even if it information concerns events within a consulate.  Was disclosure legally required?  Maybe not, at least legally.  But when you do disclose, it’s a good idea to do so honestly.  Especially if someone else gets the information.


Leave a comment

Filed under Accuracy, Communications, Compliance, Controls, Culture, Duty, Governance, Government, Information, Internal controls, To report

Compare and contrast

Europe is big on privacy.  That’s a good thing.  But perhaps not as good on freedom of speech and freedom of religion.

“Woman Who Insulted Islam Loses in Europe Court,” The Wall Street Journal, October 27, 2018 A7.  Woman fined in Austria for “disparaging” a religious doctrine, and judgment upheld by European Court of Human Rights.

So, the same place that says you have the right to be forgotten also says that you have the right not to have your religious feelings hurt.

Governing information is a tricky area, apparently, especially where the information is speech about religion. That this arose in Austria, which may because of history be especially sensitive to harming the religious feelings of others, may explain this.  Or it may not.  Is this the unintended consequence of a control that in a limited context made sense?  Or is this political, and therefore outside the normal controls?

We’re not in Kansas any more, Toto.

Leave a comment

Filed under Compliance (General), Controls, Duty, Governance, Government, Third parties

Non-disclosure non-agreement

“SEC Keeps Study On Speed-Bump Trading Under Wraps,” The Wall Street Journal, October 25, 2018 B11.  SEC has done a study of controls that slow down high-frequency traders, but hasn’t released that publicly.

The SEC is in charge of protecting the stock trading system.  As such, it watches over how quickly information moves within that ecosystem, and whether access is available to all at the same time.  But the SEC refuses to release the unredacted text of a study that it did on the impact on “controls” that limit the ability of high-speed traders to take unfair advantage of their access to information.

Curious as to why (and what) the government doesn’t want us to know.  Who oversees the government? (Hint: a free press is one of them).

Leave a comment

Filed under Access, Accuracy, Controls, Data quality, Duty, Governance, Government, Information, Interconnections, IT, Oversight, Technology, Third parties, To report, Value


“Apple CEO Urges Action on Data Misuse,” The Wall Street Journal, October 25, 2018 B1.  Tim Cook wants GDPR-style privacy protections in the US.  Claims “[o]ur own information … is being weaponized against us with military efficiency.”

He went on to suggest that the data collection practices of some online advertising companies are the equivalent of government surveillance.

How do we wrest control of our information back again?  Or is privacy dead?  And do we believe that our federal legislature is competent to develop the necessary (and effective) legal controls and protections that true Governance requires?

Leave a comment

Filed under Access, Accuracy, Analytics, Controls, Corporation, Duty, Duty of Care, Governance, Government, Information, Oversight, Ownership, Ownership, Policy, Privacy, Technology, Third parties, Value


One of the consequences of non-compliance is a higher level of scrutiny from the regulators.

“Wells Fargo Places Two Executives On Leave,” The Wall Street Journal, October 25, 2018 B10.  The Comptroller of the Currency sent letters to two WF executives about their failures of oversight at the bank in connection with WF’s sales practices.  Execs (chief administrative officer and chief auditor) placed on leave and removed from operating committee.

Boy, does that ever not look good on your resume.

Why did the regulator have to do this?  One reason is that WF didn’t do it itself.  Would your compliance system do better?  Do the directors still have their jobs?


Leave a comment

Filed under Board, Compliance, Compliance (General), Corporation, Culture, Directors, Duty, Employees, Governance, Government, Oversight, Supervision, To report

Leaker arrested

“Treasury Employee Is Accused of Leaks,” The Wall Street Journal, October 18, 2018 A4. Employee arrested for allegedly disclosing confidential banking information about Paul Manafort, among others, to a reporter at BuzzFeed.

Leaking your employer’s information is hazardous to your health and freedom.  But it’s good to know the government takes compliance seriously.

Leave a comment

Filed under Compliance, Compliance (General), Controls, Duty, Duty of Care, Employees, Governance, Government, Internal controls, Oversight, Policy, Protect assets

Is this a fire or a petition?

We all know (well, maybe) that one of the limits on the First Amendment right of freedom of speech is that you may not falsely shout “Fire!” in a crowded theater (people often omit the “falsely”).  But the First Amendment also includes the right “to petition the Government for a redress of grievances.”

“New York Probes Fake FCC Comments,”The Wall Street Journal, October 17, 2018 A4.  NY attorney general investigates the use of fake names on comments submitted to the FCC on the net neutrality issue.

Leaving aside the post-decision history of the case (US v. Schenck has been effectively overruled) and whether the statements by Justice Holmes were dicta, not law (in a case about political speech by a Socialist), it is interesting to consider whether a lobbying firm can be prosecuted (much less convicted) for misleading speech to a government agency.  From a Governance perspective, doesn’t the Constitution govern?  Don’t the lobbyists have an absolute right to petition the government?  Is the Constitution both an instrument of Governance and a control on how much the government can control Information?  Are there analogous cases involving the common law controls on an employee’s conduct?

Also, is there a point to be made here about not really knowing the context of history and famous phrases?

Leave a comment

Filed under Accuracy, Compliance, Compliance (General), Controls, Corporation, Duty, Employees, Governance, Government, Internal controls, Third parties