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Day 31 – Using a root cause analysis for remediation

Jan 31, 2022 | 31 Days to More Effective Compliance Programs

The 2020 Update re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively in practice is the extent to which a...

Day 30 – What is a root cause analysis?

Jan 30, 2022 | 31 Days to More Effective Compliance Programs

One of the biggest changes in the 2020 FCPA Resource Guide is the addition of a new Hallmark, entitled “Investigation, Analysis, and Remediation of Misconduct”, which reads in full: The truest measure of an effective compliance program is how it responds to...

Day 29 – Post-acquisition integration plan

Jan 29, 2022 | 31 Days to More Effective Compliance Programs

Your company has just made its largest acquisition ever and your CEO says they want you to have a compliance post-acquisition integration plan on their desk in one week. Where do you begin? A good place to start would be the 2020 FCPA Resource Guide language:...

Day 28 – Pre-acquisition due diligence in mergers and acquisitions

Jan 28, 2022 | 31 Days to More Effective Compliance Programs

A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks. Perhaps most commonly, inadequate due diligence can allow a course of bribery to continue – with all the attendant harms to a...

Day 27- Operationalizing Compliance Through Payroll

Jan 27, 2022 | 31 Days to More Effective Compliance Programs

One of the areas articulated in the 2020 Update was around payments and payroll. For the both the compliance professional and the corporate payroll function, there is a significant role to play in the operationalization of a corporate compliance program. The 2020...

Day 26 – Compliance function in an organization

Jan 26, 2022 | 31 Days to More Effective Compliance Programs

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it came to the corporate compliance function, 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance...

Day 25 – CCO authority and independence

Jan 25, 2022 | 31 Days to More Effective Compliance Programs

The role of the CCO has steadily grown in stature and prestige over the years. In the 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, it focused on the whether the CCO held senior management status and had a direct reporting line to...

Day 24 – Updates and feedback

Jan 24, 2022 | 31 Days to More Effective Compliance Programs

One of the critical elements found in the 2020 Update is the need to use the information you obtain, whether through risk assessment, root cause analysis, investigation, hotline report or any other manner to remediate the situation which allowed it to arise. Your...

Day 23 – Assessing Compliance Internal Controls

Jan 23, 2022 | 31 Days to More Effective Compliance Programs

What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities which violate the FCPA or some other law such as Sarbanes-Oxley (SOX). Cristina Revelo said she would start out with some basic questions such...

Day 22 – Internal Reporting and Triaging Claims

Jan 22, 2022 | 31 Days to More Effective Compliance Programs

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 be up to you to begin the process which will determine, in many...
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