Day 7 | Policies and Procedures
There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the government comes knocking. The Evaluation of Corpo...
7 Jan 20209min
Day 6 | The Code of Conduct
What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to wave in regulator’s face during an enforcement action as proof of e...
6 Jan 20209min
Fry Wernick on the Hoskins Jury Instructions
In the Episode, I visit with Ephraim (Fry) Wernick. He is a partner in the Government Investigations and White-Collar Practice Group at Vinson & Elkins LLP in Washington, DC. Mr. Wernick joined V&E in...
6 Jan 202024min
Day 5 | The Board and operationalizing compliance
In addition to a company’s senior management, there is a Board of Directors at the top. Yet the role of the Board is different than that of senior management. For the Board of Director, the Evaluation...
5 Jan 20209min
Day 4 | Moving compliance tone down through an organization
Mike Volkov, in a blog post entitled “Mood in the Middle Versus Tone at the Top”, said, “Even when a company does all the right things at the senior management level, the real issue is whether or not ...
4 Jan 20209min
Day 3 | Leadership’s conduct at the top
Obviously, in every compliance program, the ethical tone of a company and accountability all starts at the top and most specifically senior management. The Evaluation of Corporate Compliance Programs ...
3 Jan 20208min
Day 2 | Measuring your risk
Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program within the contours of your organization is an import...
2 Jan 20208min
Day 1 | What 2019 Brought to Compliance Programs
2019 was a very significant year for every compliance practitioner and compliance program. Not only was it the year with the single highest amount of FCPA enforcement actions, fines and penalties asse...
1 Jan 20209min
