• One Month to Operationalizing your Compliance Program

  • By: Tom Fox
  • Podcast

One Month to Operationalizing your Compliance Program

By: Tom Fox
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  • Summary

  • a monthly series where Compliance Evangelist Tom Fox tackles the subject of a best practices compliance program. Different months have themes like boards of directors and their role in compliance, investigations, third parties and the role of HR and internal controls.
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Economics
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Episodes
  • Day 31 of 31 Days to a More Effective Compliance Program

    Day 31 of 31 Days to a More Effective Compliance Program
    Jan 31 2018
    I next want to take a deep dive and exploration of the levels of due diligence. 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 risk. The key is for you to develop a mechanism to determine the appropriate level of due diligence and then implement that going forward.
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    11 mins
  • Day 30 of 31 Days to a More Effective Compliance Program

    Day 30 of 31 Days to a More Effective Compliance Program
    Jan 30 2018
    We previously considered the Prong in the Evaluation of Corporate Compliance Programs which was not present in the Ten Hallmarks of an Effective Compliance Program; that being root cause analysis. This addition was also carried forward as a requirement in the Department of Justice’s new FCPA Corporate Enforcement Policy. I want to consider how you should utilize the results of a root cause analysis in remediating a compliance program.
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    12 mins
  • Day 29 of 31 Days to a More Effective Compliance Program

    Day 29 of 31 Days to a More Effective Compliance Program
    Jan 29 2018
    One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root cause analysis for any compliance violation which may led to a self-disclosure or enforcement action.
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    11 mins

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