Day 21 | Continuous improvement in a compliance program
The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One...
21 Jan 20209min
Day 20 | Responding to investigative findings
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from the DOJ or notice letter from the SEC to trigger the ...
20 Jan 20209min
Dave Lefort on 10 Stories CW Will Follow in 2020
In the Episode, I visit with Dave Lefort, Editor in Chief for Compliance Week. Dave recently wrote “It’s hard to tell whether the age we’re living in is the calm before the storm or if it is the storm...
20 Jan 202035min
Day 19 | The investigation protocol
After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. Your company should have a det...
19 Jan 20209min
Day 18 | Internal reporting and the triaging of claims
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will...
18 Jan 20209min
Day 17 | Managing your third parties
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners un...
17 Jan 20209min
Day 16 | The third-party risk management process
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) devotes...
16 Jan 20209min
Day 15 | How do you evaluate a risk assessment?
After you complete your risk assessment, you must then translate it into a risk profile. If your estimate of where your bribery risk is greatest is wrong, it will be an effort to address it. As Ben Lo...
15 Jan 20209min
