31 Days to a More Effective Compliance Program
Episodes
Day 24 - Updates and feedback
24 Jan 2023
Contributed by Lukas
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 analy...
Day 23 - Assessing Compliance Internal Controls
23 Jan 2023
Contributed by Lukas
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities which violate the FCPA or ...
Day 22 - Internal Reporting and Triaging Claims
22 Jan 2023
Contributed by Lukas
The call, email, or tip comes into your office; an employee reports suspicious activity across the globe. That activity might well turn into an FCPA i...
Day 21 - Continuous improvement in a compliance program
21 Jan 2023
Contributed by Lukas
The 2020 Update was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One hallmark of an ...
Day 20 - Responding to investigative findings
20 Jan 2023
Contributed by Lukas
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...
Day 19 - Your investigation protocol
19 Jan 2023
Contributed by Lukas
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 c...
Day 18 - Levels of due diligence
18 Jan 2023
Contributed by Lukas
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption ...
Day 17- Managing your third parties
17 Jan 2023
Contributed by Lukas
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management ...
Day 16 - The third-party risk management process
16 Jan 2023
Contributed by Lukas
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA even in 2023. The 2020 Update devotes an e...
Day 15 - How do you evaluate a risk assessment?
15 Jan 2023
Contributed by Lukas
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 wr...
Day 14 - Risk Assessments
14 Jan 2023
Contributed by Lukas
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program sho...
Day 13: Podcasting for Compliance Training and Communication
13 Jan 2023
Contributed by Lukas
If there is one truism from the practice of law which translates to the practice of compliance it is that you are only limited by your own imagination...
Day 12 - Financial Incentives for Compliance
12 Jan 2023
Contributed by Lukas
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation and incentives. However, the DOJ ...
Day 11 - Tailored and Effective Compliance Training
11 Jan 2023
Contributed by Lukas
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance prog...
Day 10 - The Use of Social Media in Compliance
10 Jan 2023
Contributed by Lukas
What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/cu...
Day 9 - 360 Degrees of Compliance Communications
09 Jan 2023
Contributed by Lukas
A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and ...
Day 8 - Internal Controls and Compliance
08 Jan 2023
Contributed by Lukas
What are internal controls? The best definition I have come across is from Jonathan Marks who defined internal controls as: An internal control is a...
Day 7 - Policies and Procedures
07 Jan 2023
Contributed by Lukas
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 ...
Day 6 - The Code of Conduct
06 Jan 2023
Contributed by Lukas
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...
Day 5 - The Board of Directors and Operationalizing Compliance
05 Jan 2023
Contributed by Lukas
The most significant development for Boards and compliance in continues to come from the Delaware courts, which have been expanding the civil law obli...
Day 4 - Moving Compliance Tone Down Through an Organization
04 Jan 2023
Contributed by Lukas
What should the tone in the middle be? What should middle management’s role be in the company’s compliance program? This role is critical because ...
Day 3 - Leadership’s Conduct at the Top
03 Jan 2023
Contributed by Lukas
DAG Lisa Monaco’s speech in September 2022 announcing the Monaco Memo as articulated in the Monaco Doctrine laid out the very basics of compliance; ...
Day 2 - Continuous Monitoring and Continuous Improvement
02 Jan 2023
Contributed by Lukas
Continuous monitoring and improvement are two of the most important phrases for any compliance program. These twin concepts were perhaps the biggest m...
Day 1 - What 2022 Brought To Compliance Programs
01 Jan 2023
Contributed by Lukas
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in Ja...
Day 31 - Using a root cause analysis for remediation
31 Jan 2022
Contributed by Lukas
The 2020 Update re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program...
Day 30 - What is a root cause analysis?
30 Jan 2022
Contributed by Lukas
One of the biggest changes in the 2020 FCPA Resource Guide is the addition of a new Hallmark, entitled “Investigation, Analysis, and Remediation of ...
Day 29 - Post-acquisition integration plan
29 Jan 2022
Contributed by Lukas
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 thei...
Day 28 - Pre-acquisition due diligence in mergers and acquisitions
28 Jan 2022
Contributed by Lukas
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,...
Day 27- Operationalizing Compliance Through Payroll
27 Jan 2022
Contributed by Lukas
One of the areas articulated in the 2020 Update was around payments and payroll. For the both the compliance professional and the corporate payroll fu...
Day 26 - Compliance function in an organization
26 Jan 2022
Contributed by Lukas
The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When i...
Day 25 - CCO authority and independence
25 Jan 2022
Contributed by Lukas
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 Co...
Day 24 - Updates and feedback
24 Jan 2022
Contributed by Lukas
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 analy...
Day 23 - Assessing Compliance Internal Controls
23 Jan 2022
Contributed by Lukas
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities which violate the FCPA or ...
Day 22 - Internal Reporting and Triaging Claims
22 Jan 2022
Contributed by Lukas
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into ...
Day 21 - Continuous improvement in a compliance program
21 Jan 2022
Contributed by Lukas
The 2020 Update was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One hallmark of an ...
Day 20 - Responding to Investigative Findings
20 Jan 2022
Contributed by Lukas
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...
Day 19 - The investigation protocol
19 Jan 2022
Contributed by Lukas
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 c...
Day 18 - Levels of due diligence
18 Jan 2022
Contributed by Lukas
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption ...
Day 17 - Managing your third parties
17 Jan 2022
Contributed by Lukas
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management ...
Day 16 - The third-party risk management process
16 Jan 2022
Contributed by Lukas
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong t...
Day 15 - How Do You Evaluate a Risk Assessment?
15 Jan 2022
Contributed by Lukas
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 wr...
Day 14 - Risk Assessments
14 Jan 2022
Contributed by Lukas
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program sho...
Day 13 - Institutional Justice and Institutional Fairness
13 Jan 2022
Contributed by Lukas
Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employ...
Day 12 - Financial Incentives for Compliance
12 Jan 2022
Contributed by Lukas
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have lo...
Day 11 - Tailored and Effective Compliance Training.
11 Jan 2022
Contributed by Lukas
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance prog...
Day 10 - The Use of Social Media in Compliance
10 Jan 2022
Contributed by Lukas
What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/cu...
Day 9 - 360 Degrees of Compliance Communications
09 Jan 2022
Contributed by Lukas
A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and ...
Day 8 - Internal Controls and Compliance
08 Jan 2022
Contributed by Lukas
What are internal controls? The best definition I have come across is from Jonathan Marks who defined internal controls as: An internal control is a...
Day 7 - Policies and Procedures
07 Jan 2022
Contributed by Lukas
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 ...
Day 6 - The Code of Conduct
06 Jan 2022
Contributed by Lukas
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...
Day 5 - The Board and Operationalizing Compliance
05 Jan 2022
Contributed by Lukas
The most significant development for Boards and compliance in 2021 came from the Delaware courts, which have been expanding the civil law obligations ...
Day 4 - Moving Compliance Tone Down Through an Organization
04 Jan 2022
Contributed by Lukas
Mike Volkov has said, “Even when a company does all the right things at the senior management level, the real issue is whether or not that culture h...
Day 3 - Leadership’s Conduct at the Top
03 Jan 2022
Contributed by Lukas
DAG Lisa Monaco’s speech on FCPA enforcement and compliance laid out the very basics; that the key to every company is culture. She stated, “corpo...
Day 2 - Continuous Monitoring and Continuous Improvement
02 Jan 2022
Contributed by Lukas
Continuous monitoring and continuous improvement are two of the most important phrases for any compliance program. These twin concepts were perhaps th...
Day 1-What 2021 Brought to Compliance
01 Jan 2022
Contributed by Lukas
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in Ja...
Day 31 | Using a root cause analysis for remediation
31 Jan 2021
Contributed by Lukas
The 2020 Update re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program...
Day 30 | What is a root cause analysis?
30 Jan 2021
Contributed by Lukas
One of the biggest changes in the 2020 FCPA Resource Guide is the addition of a new Hallmark, entitled “Investigation, Analysis, and Remediation of ...
Day 29 | Post-acquisition integration plan
29 Jan 2021
Contributed by Lukas
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 thei...
Day 28 | Pre-acquisition due diligence in mergers and acquisitions
28 Jan 2021
Contributed by Lukas
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,...
Day 27 | Operationalizing compliance through payroll
27 Jan 2021
Contributed by Lukas
One of the areas articulated in the 2020 Update was around payments and payroll. For the both the compliance professional and the corporate payroll fu...
Day 26 | Compliance function in an organization
26 Jan 2021
Contributed by Lukas
The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When i...
Day 25 | CCO authority and independence
25 Jan 2021
Contributed by Lukas
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 Co...
Day 24 | Updates and feedback
24 Jan 2021
Contributed by Lukas
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 analy...
Day 23 | Assessing compliance internal controls
23 Jan 2021
Contributed by Lukas
One of the specific requirements laid out in the 2020 Update, is around internal controls and more specifically control testing. It stated: Control Te...
Day 22 | Internal reporting and triaging claims
22 Jan 2021
Contributed by Lukas
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into ...
Day 21 | Continuous improvement in a compliance program
21 Jan 2021
Contributed by Lukas
The 2020 Update was very clear about the need for continuous improvement in any compliance program. It stated quite succinctly, “One hallmark of an ...
Day 20 | Responding to investigative findings
20 Jan 2021
Contributed by Lukas
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...
Day 19 | The investigation protocol
19 Jan 2021
Contributed by Lukas
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 c...
Day 18 | Levels of due diligence
18 Jan 2021
Contributed by Lukas
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption ...
Day 17 | Managing your third parties
17 Jan 2021
Contributed by Lukas
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management ...
Day 16 | The third-party risk management process
17 Jan 2021
Contributed by Lukas
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong t...
Day 15 | How do you evaluate a risk assessment?
15 Jan 2021
Contributed by Lukas
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 wr...
Day 14 | Risk Assessments
14 Jan 2021
Contributed by Lukas
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program sho...
Day 13 | Institutional Justice and Fairness
13 Jan 2021
Contributed by Lukas
Companies have finally come to realize that institutional justice and fairness are perhaps the most basic tenet of any successful workplace. If employ...
Day 12 | Financial Incentives for Compliance
12 Jan 2021
Contributed by Lukas
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. However, the DOJ and SEC have lo...
Day 11 | What is Effective Compliance Training?
11 Jan 2021
Contributed by Lukas
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance prog...
Day 10 | The Use of Social Media in Compliance
10 Jan 2021
Contributed by Lukas
What is the message of compliance inside of a corporation and how it is distributed? In a compliance program, the largest portion of your consumers/cu...
Day 9 | 360 Degrees of Compliance Communications
09 Jan 2021
Contributed by Lukas
A 360-degree view of compliance is an effort to incorporate your compliance identity into a holistic approach so that compliance is in touch with and ...
Day 8 | Internal Controls and Compliance
08 Jan 2021
Contributed by Lukas
What are internal controls? The best definition I have come across is from Jonathan Marks who defined internal controls as: An internal control is...
Day 7 | Policies and Procedures
07 Jan 2021
Contributed by Lukas
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 ...
Day 6 | The Code of Conduct
06 Jan 2021
Contributed by Lukas
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...
Day 5 | The Board and Operationalizing Compliance
05 Jan 2021
Contributed by Lukas
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 m...
Day 4 | Moving Compliance Tone Down Through An Organization
04 Jan 2021
Contributed by Lukas
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 se...
Day 3 | Leadership’s Conduct At The Top
03 Jan 2021
Contributed by Lukas
Obviously, in every compliance program, the ethical tone of a company and accountability all starts at the top and, most specifically, senior manageme...
Day 2 | Continuous Monitoring and Continuous Improvement
02 Jan 2021
Contributed by Lukas
I want to next focus specifically on the tactical steps of moving towards both continuous monitoring and continuous improvement of your compliance pro...
Day 1 | What 2020 Brought To Compliance Programs
01 Jan 2021
Contributed by Lukas
2020 was a very significant year for every compliance practitioner and compliance program. Not only was it the year with the single highest anti-bribe...
Compliance training from the movies
30 Dec 2020
Contributed by Lukas
If there is one truism from the practices of law which translates to the practice of compliance it is that you are only limited by your own imaginatio...
Measuring Compliance Training Effectiveness
29 Dec 2020
Contributed by Lukas
Since at least 2017, the DOJ has emphasized the need for a determination of compliance training effectiveness. In the 2020 Update, it stated under the...
Compliance Training Frequency
28 Dec 2020
Contributed by Lukas
What should be your organization’s compliance training frequency? How does the amount of training can positively or negatively impact an overall tra...
Why You Should Have a Compliance Training Governance Committee
23 Dec 2020
Contributed by Lukas
One issue not often considered by compliance professionals around compliance training is that of compliance training governance. Yet a multinational o...
Ten Compliance Training Program Design Objectives
22 Dec 2020
Contributed by Lukas
Shawn Rogers, Senior Director, Global Training & Awareness, Walmart has developed ten design objectives for establishing your compliance program trai...
Envisioning Your Compliance Training Program
21 Dec 2020
Contributed by Lukas
How can you begin to think through a best practices compliance training program? I put that question to Shawn Rogers, Senior Director, Global Training...
Twitter and 360-degrees of communication
18 Dec 2020
Contributed by Lukas
One of the ways that CCOs and compliance practitioners can better use 360-degrees of communication is through Twitter. In a MIT Sloan Management Re...
Asking questions to boost your compliance program
17 Dec 2020
Contributed by Lukas
Other than the skill of listening, asking questions is about as important to the compliance practitioner as any other that can be employed. Yet, equal...
Communicating across cultural boundaries
16 Dec 2020
Contributed by Lukas
A 360-degree approach to communications entails looking at all forms of interactions as a way to interconnect. This means both verbal and non-verbal a...
Multiplying the influence of compliance
15 Dec 2020
Contributed by Lukas
What if you could multiply the impact and effectiveness of your compliance program throughout your company? That would be a great boon to any complian...
Communication through persuasion
14 Dec 2020
Contributed by Lukas
Such small gestures can make a difference. I recently read a biography of Dale Carnegie by Steven Watts, entitled “Self-Help Messiah: Dale Carnegie...
Using communications to foster your compliance brand
11 Dec 2020
Contributed by Lukas
Our next lesson on compliance communications comes from best-selling authors James Patterson and David Baldacci and it about your brand. I had always ...
Using Communications to Drive a Speak Up Culture
10 Dec 2020
Contributed by Lukas
How often have you thought about the role of communications in your entire hotline reporting system? I do not mean posters giving the hotline number, ...
Using 360 Degree of Compliance to Tell a Story
09 Dec 2020
Contributed by Lukas
The 360-degree approach to compliance works with all the stakeholders in a compliance program, even the “Document, Document, and Document” stakeho...