Day 2 of 30 Days to Operationalize Your Compliance Program

Day 2 of 30 Days to Operationalize Your Compliance Program

The Evaluation, most generally, follows the DOJ and Securities and Exchange Commission’s (SEC) seminal Ten Hallmarks of an Effective Compliance Program, released in the 2012 FCPA Guidance. If there is one over-riding theme in the Evaluation, it is the DOJ’s emphasis on operationalizing your compliance program as the questions posed are designed to test how far down your compliance program is incorporated into the very DNA and fabric of your organization. The Evaluation is not simply a restatement of the Ten Hallmarks, as it clearly incorporates the DOJ’s evolution in what constitutes a best practices compliance program over the past 18 months and it certainly builds upon the information put forward in the DOJ’s FCPA Pilot Program regarding effective compliance programs, most particularly found in Prong 3 Remediation. Three Key Takeaways The Evaluation follows a consistent theme of DOJ pronouncement over the past 18 on to operationalize your compliance program. There is one new area with a focus on root cause analysis and risk assessments. There is a greater consideration of how the CCO is treated and viewed within an organization. Learn more about your ad choices. Visit megaphone.fm/adchoices

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Episoder(1623)

9/11 Twenty-Five Years Later: Part 3: Alex Dill - Patriot Act: The AML Response to Terrorist Threats

9/11 Twenty-Five Years Later: Part 3: Alex Dill - Patriot Act: The AML Response to Terrorist Threats

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget. On the ...

8 Sep 19min

9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds

9/11 Twenty-Five Years Later: Part 2: Juan Zarate - The Treasury Department Responds

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget. On the ...

7 Sep 18min

9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference

9/11 Twenty-Five Years Later: Part 1: Gabe Hidalgo - Needing to Make a Difference

Ed. Note-Five years ago, I looked back on 9/11 in a 20 year retrospective. This week is the 25th anniversary of that event. I am rerunning this award winning podcast so that we never forget. On the ...

6 Sep 20min

Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

Mara Senn on AI-Native, Human-in-the-Loop Investigations for Compliance

In this episode, Tom Fox welcomes Mara Senn, founder and CEO of Ethakos, about her path from big law and a decade as a partner at Arnold & Porter to anti-corruption work at the Kleptocracy Initiative,...

31 Aug 31min

Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

Charisma Doesn’t Scale, Controls Do: Compliance Lessons from Ted Lasso

In this episode, I take things in a very different direction. Last week I did a 5-part blog post series on leadership lessons from the hit TV show Ted Lasso. I took those 5 blog posts and fed them int...

24 Aug 24min

Data Analytics in Compliance: Lessons from Scoular

Data Analytics in Compliance: Lessons from Scoular

In this episode, Tom Fox welcomes back Vince Walden, CEO of konaAI, which is the sponsor of this podcast series. Vince is well known for his leadership in data analytics, machine learning, and AI, and...

17 Aug 29min

The Berko Verdict with Mike Volkov

The Berko Verdict with Mike Volkov

In this episode, Tom Fox welcomes back his good friend and colleague Mike Volkov and takes a deep dive into the Asante Berko FCPA guilty verdict. They question why Berko went to trial given the stren...

10 Aug 33min

Matt Ellis Wrap-Up from Cartels, FTO Risk, and Corporate Compliance Conference

Matt Ellis Wrap-Up from Cartels, FTO Risk, and Corporate Compliance Conference

In this episode, Tom Fox welcomes back Matt Ellis of Miller & Chevalier to recap ACI’s inaugural two-day Cartel Conference in Washington, DC, highlighting an unusually collaborative, high-energy atmos...

3 Aug 36min

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