31 Days to a More Effective Compliance Program
Episodes
Succession planning around compliance
17 Feb 2020
Contributed by Lukas
Another area where Human Resources can help to more fully operationalize compliance is in succession planning. Succession planning is just as importa...
Institutional Justice and The Fair Process Doctrine
14 Feb 2020
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...
Sales incentives and compliance
13 Feb 2020
Contributed by Lukas
In the DOJ’s 2019 Guidance, Incentives and Disciplinary Measures it stated: Incentive System – Has the company considered the implications of i...
Executives Compensation and compliance incentives
12 Feb 2020
Contributed by Lukas
A 2015 New York Times article by Gretchen Morgenson, entitled “Ways to Put the Boss’s Skin In the Game”, dealt with a long-standing question a...
Designing compensation to operationalize compliance
11 Feb 2020
Contributed by Lukas
One of the areas that many companies have not paid as much attention to in their anti-corruption compliance programs is designing their compensation s...
Six core principles for compliance incentives
10 Feb 2020
Contributed by Lukas
Most compliance professionals understand the need to discipline employees who may have violated ethics and compliance programs or otherwise engaged in...
The Role of Human Resources in Incentivizing Compliance
07 Feb 2020
Contributed by Lukas
One of the key points that representatives of the DOJ and Securities and Exchange Commission (SEC) have continually raised when discussing any best pr...
Using the Reference Check to Operationalize Compliance
06 Feb 2020
Contributed by Lukas
As far back as 2004, in Opinion Release 04-02, the DOJ realized this was an important part of an overall compliance program when it approved a propos...
The Hiring Process as a Step to Operationalize Compliance
05 Feb 2020
Contributed by Lukas
One of the conventional wisdoms about compliance training is that you will never be able to reach 5% of your workforce with compliance training becaus...
The Role of HR in Creating an Ethical Culture
04 Feb 2020
Contributed by Lukas
The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done ...
The Role of Human Resources in Operationalizing Compliance-Introduction
03 Feb 2020
Contributed by Lukas
Ed. Note-my series in January, 31 Days to a More Effective Compliance Program, was so popular, I decided to extend it through 2020. Each month, I will...
Day 31 | Levels of due diligence
31 Jan 2020
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 30 | Using a root cause analysis for remediation
30 Jan 2020
Contributed by Lukas
We previously considered the Prong in the Evaluation that was not present in the Ten Hallmarks of an Effective Compliance Program; that being root ca...
Day 29 | What is a root cause analysis?
30 Jan 2020
Contributed by Lukas
Well known fraud investigator Jonathan Marks, defined a root cause analysis as “a research based approach to identifying the bottom line reason of ...
Day 28 | Post-acquisition integration plan
30 Jan 2020
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 27 | Pre-acquisition due diligence in mergers and acquisitions
30 Jan 2020
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 26 | Operationalizing compliance through payroll
26 Jan 2020
Contributed by Lukas
One of the areas articulated in the 2019 Guidance was around payments and payroll. For the both the compliance professional and the corporate payroll...
Day 25 | Compliance function in an organization
25 Jan 2020
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 24 | CCO authority and independence
24 Jan 2020
Contributed by Lukas
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 Ten Hallmarks of...
Day 23 | Updates and feedback
23 Jan 2020
Contributed by Lukas
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 an...
Day 22 | Assessing compliance internal controls
22 Jan 2020
Contributed by Lukas
Control Testing – Has the company reviewed and audited its compliance program in the area relating to the misconduct? More generally, what testing...
Day 21 | Continuous improvement in a compliance program
21 Jan 2020
Contributed by Lukas
The Evaluation of Corporate Compliance Programs - Guidance Document (2019 Guidance) was very clear about the need for continuous improvement in any ...
Day 20 | Responding to investigative findings
19 Jan 2020
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 2020
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 | Internal reporting and the triaging of claims
19 Jan 2020
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 17 | Managing your third parties
19 Jan 2020
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
19 Jan 2020
Contributed by Lukas
As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The Evaluation of Corporate Complianc...
Day 15 | How do you evaluate a risk assessment?
15 Jan 2020
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 2020
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 The Fair Process Doctrine
13 Jan 2020
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 2020
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 2020
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 2020
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 2020
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 2020
Contributed by Lukas
What specifically are internal controls in a compliance program? The starting point is the FCPA itself, which requires issuers to devise and maintain ...
Day 7 | Policies and Procedures
07 Jan 2020
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
07 Jan 2020
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
03 Jan 2020
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
03 Jan 2020
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 2020
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 management...
Day 2 | Measuring your risk
03 Jan 2020
Contributed by Lukas
Operationalizing your compliance program can take many shapes and forms. Using the entire risk management process to embed your compliance program wit...
Day 1 | What 2019 Brought to Compliance Programs
03 Jan 2020
Contributed by Lukas
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 ...