Day 6 of One Month to Operationalizing Your Compliance Program
The DOJ Evaluation of Corporate Compliance Programs states: Risk Management Process – What methodology has the company used to identify, analyze, and address the particular risks it faced? Informat...
8 Mar 201712min
Compliance into the Weeds-Episode 30
The Justice Department Fraud Section recently revamped its website and it is quite an upgrade. I do not know when the Fraud Section did this update but as with the Evaluation of Corporate Compliance P...
8 Mar 201718min
Day 5 of One Month to Operationalizing Your Compliance Program
At its heart, every business tries to plan for its future. It is a critical aspect of any management of any organization, non-profits, privately owned for profits and, of course, publicly traded compa...
7 Mar 201713min
FCPA Compliance Report-Episode 312, Ben Locwin
In this Part III to a three part podcast series, I visit with noted risk management expert, Ben Locwin on risk-based monitoring as a adjunct to forecasting and risk assessments. We discuss how to acco...
7 Mar 201720min
Day 4 of One Month to Operationalizing Your Compliance Programs
Analysis and Remediation of Underlying Misconduct Root Cause Analysis – What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified? Who in the company...
6 Mar 201712min
This Week in FCPA-Episode 42
Jay Rosen and I dedicate the entire episode to the FUBAR surrounding the Oscar ceremony where the Best Picture award was given to the wrong picture. We consider the control failures around the inciden...
3 Mar 201725min
Day 3 of One Month to Operationalizing Your Compliance Program
Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section in February. The document is an 11-part ...
3 Mar 201713min
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...
2 Mar 201711min
