Day 24 | CCO authority and independence
January 24, 2020
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The role of the CCO has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the
The role of the CCO has steadily grown in stature and prestige over the years. In the 2012 FCPA Guidance, under Hallmark Three of the
One of the critical elements found in the 2019 Guidance is the need to use the information you obtain, whether through risk assessment, root cause analysis,
Control Testing – Has the company reviewed and audited its compliance program in the area relating to the misconduct? More generally, what testing of controls,
The Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance) was very clear about the need for continuous improvement in any compliance program. It
There is nothing like an internal whistleblower report about a compliance violation, the finding of such an issue, or (even worse) a subpoena from
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
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
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
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The Evaluation of Corporate Compliance Programs – Guidance
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
