Day: January 20, 2020

31 Days to More Effective Compliance Programs

Day 20 | Responding to investigative findings

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Post date January 20, 2020
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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 Board of Directors and senior management attention to the compliance function and the company’s compliance program. Such an event can trigger much gnashing of teeth and expressions of outrage followed immediately by proclamations “We are an ethical company.” However, it may well be the time for a very serious reality check.
Three key takeaways:

A serious FCPA allegation gets the attention of the Board and senior management. Use this time to move the compliance program forward.
Be aware of how your investigation can impact and even inform your remediation efforts.
Be prepared to deal with the dreaded “where else” question.

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FCPA Compliance Report

Dave Lefort on 10 Stories CW Will Follow in 2020

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Post date January 20, 2020
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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. One way or another, we’ll likely get some clarity in the year ahead for CCOs navigating these choppy waters.” I asked him to come on the podcast and discuss his 10 predictions on what will dominate compliance headlines in 2020.

Big Tech in antitrust crosshairs. Is everyone ganging up on big tech?
Deregulation. Is it real or is it Memorex?
Recession worries: Impact on ethics and compliance. Will compliance have to do more with less or less with less?
2020 elections. How could it impact the regulatory environment heading into 2021?
Protecting whistleblowers. Will Congress step in where the Supreme Court gutted protection? Will Trump’s public berating of the impeachment whistleblower embolden those accused of wrongdoing to retaliate?
Data privacy equation has changed. How so?
GDPR: Waiting for the big one. Which US company will it be?
Regulators will reward good-faith efforts. Is it softening or a refocus?
Ethics and Artificial Intelligence: Trouble ahead? Will Skynet become self-aware?
Supply chains, geopolitical risk, and third parties. If this is such a big problem, where are the resources to fix it?

Resources
Dave’s article Ten Things We’ll Be Talking About in 2020
Subscribe to Compliance Week here. Use the code, NEWYEAR2020 … for a $365 for a one-year membership.
Register for Compliance Week 2020, here.