Day 31 | Using a root cause analysis for remedi...
How should you utilize a root cause analysis for remediation going forward?
Day 30 | What is a root cause analysis?
What is a root cause analysis and how should you utilize it?
Day 29 | Post-acquisition integration plan
What is your post-acquisition integration?
Day 28 | Pre-acquisition due diligence in merge...
A company that does not perform adequate due diligence prior to a merger or acquisition may face both legal and business risks.
Day 27 | Operationalizing compliance through pa...
How can payroll help to operationalize your compliance program?
Day 26 | Compliance function in an organization
The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years.
Day 25 | CCO authority and independence
How can you show the authority and independence of the CCO?
Day 24 | Updates and feedback
How can you engage in continuous monitoring and continuous feedback? Through updates and feedback.
Day 23 | Assessing compliance internal controls
How can you assess internal controls? Find out in this episode of 31 Days to a More Effective Compliance Program
Day 22 | Internal reporting and triaging claims
How should you think through a response to internal reporting. By triaging claims.
Day 21 | Continuous improvement in a compliance...
Why is continuous improvement a mainstay of every compliance program? Find out in 31 Days to a More Effective Compliance Program
Day 20 | Responding to investigative findings
How should you respond to investigative findings? Through remediation.
Day 19 | The investigation protocol
Why must you have an investigation protocol? Find out in this episode of 31 Days to a More Effective Compliance Program
Day 18 | Levels of due diligence
What are the levels of due diligence and how to utilize them?
Day 17 | Managing your third parties
Why is managing third-parties the most important step in the 3rd Party Risk Management Cycle?
Day 16 | The third-party risk management process
What is the 5-step process for 3rd party risk management? Find out in today's 31 Days to a More Effective Compliance Program.
Day 15 | How do you evaluate a risk assessment?
How do you evaluate a risk assessment? Find out in this episode of 31 Days to a More Effective Compliance Program.
Day 14 | Risk Assessments
Risk assessments are the cornerstone of any compliance program.
Day 13 | Institutional Justice and Fairness
Instituional justice is the bulwark of any corporate culture and compliance program.
Day 12 | Financial Incentives for Compliance
One of the areas that many companies have not paid as much attention to in their compliance programs is compensation. Find out why you should on this episode of 31 Days to a More Effective Compliance Program.
Day 11 | What is Effective Compliance Training?
How do you determine the effectiveness of your compliance training?
Day 10 | The Use of Social Media in Compliance
Social media presents the compliance professional excellent mechanisms to communicate the message of compliance going forward.
Day 9 | 360 Degrees of Compliance Communications
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 visible to your employees at all times.
Day 8 | Internal Controls and Compliance
What are internal controls and what is their place in a best practices compliance program.?
Day 7 | Policies and Procedures
There are numerous reasons to put some serious work into your compliance policies and procedures.
Day 6 | The Code of Conduct
What is the value of having a Code of Conduct? What should be the goal in the creation of your company’s Code of Conduct?
Day 5 | The Board and Operationalizing Compliance
What is the role of the Board in operationalizing compliance?
Day 4 | Moving Compliance Tone Down Through An ...
How can you move compliance tone down through an organization?
Day 3 | Leadership’s Conduct At The Top
This requirement is more than simply the ubiquitous “tone-at-the-top,” as it focuses on the conduct of senior management.
Day 2 | Continuous Monitoring and Continuous Im...
Some of the biggest changes from the past year were around continuous monitoring and continuous improvement.
Day 1 | What 2020 Brought To Compliance Programs
In this episode of 31 Days to a More Effective Compliance Program, I highlight what 2020 Brought To Compliance Programs.
Compliance training from the movies
How can movies be a great compliance training tool? Find out in today's episode of 31 Days to a More Effective Compliance Program.
Measuring Compliance Training Effectiveness
Since at least 2017, the DOJ has emphasized the need for a determination of compliance training effectiveness. Find out how to do so in today's 31 Days to a More Effective Compliance Program.
Compliance Training Frequency
What should be your organization’s compliance training frequency? Find out more in today's 31 Days to a More Effective Compliance Program.
Why You Should Have a Compliance Training Gover...
A Compliance Training Governance Committee can help create a comprehensive compliance training program that covers your complete risk profile.
Ten Compliance Training Program Design Objectives
Shawn Rogers has developed ten design objectives for establishing your compliance program training design objectives. You should consider doing the same for your organization.
Envisioning Your Compliance Training Program
How can you begin to think through a best practices compliance training program? To begin you ‘envision’ what your training would like as a first step.
Twitter and 360-degrees of communication
Twitter can be powerful tool for the compliance practitioner.
Asking questions to boost your compliance program
Asking questions does more than elicit information; it also creates the space for people to raise issues.
Communicating across cultural boundaries
How can a 360-degree approach help in relating to and with cultures outside the US? Find out in today's 31 Days to a More Effective Compliance Program.
Multiplying the influence of compliance
What if you could multiply the impact and effectiveness of your compliance program throughout your company? Find out how in today's 31 Days to a More Effective Compliance Program
Communication through persuasion
How can you communicate through persuasion? Find out in today's 31 Days to a More Effective Compliance Program
Using communications to foster your compliance ...
Always remember, your brand is not an image but is about your relationship with your stakeholders.
Using Communications to Drive a Speak Up Culture
How often have you thought about the role of communications in your entire hotline reporting system?
Using 360 Degree of Compliance to Tell a Story
The 360-degree approach to compliance works with all the stakeholders in a compliance program, even the “Document, Document, and Document” stakeholders; i.e., the regulators.
Compliance and the clash of cultures
How can communications help overcome the clash of cultures in compliance?
Sharing to 360-degrees of communication
Why do people share information? The answer to that question has important implications for every compliance practitioner and compliance program.
Using social media to innovate in compliance
How can you get your arms around how to structure such a program for your company? The most important thing to remember is that communication in social media is two-way; both inbound and outbound.
The D&B experience in 360 Degrees of Communicat...
How has one company and one CCO actively use social media to make the company’s compliance culture more effective?
Social media is a 360-degree conversation
Social media presents some excellent mechanisms to communicate the message of compliance going forward.
Introduction To December- Training and Communic...
In this month's offering of 31 Days to a More Effective Compliance Program, you will learn about training and communication techniques that the CCO can use.
Leveraging AI in Compliance Investigations
Leveraging AI is now critical in compliance investigations.
Creating an Inventory of Metrics
Why is the creation of an inventory of metrics, a critical step in building a best practices compliance program?
Consistency as a Compliance Best Practice
Why is consistency a best practice in compliance? Find out in today's edition of 31 Days to a More Effective Compliance Program.
Compliance at the Table
Why must compliance have a seat at the table in the 2020s? Find out on today's episode of 31 Days to a More Effective Compliance Program
Compliance Innovation Through KPIs
How can you innovate your compliance program though the use of KPIs? Find out on Today's edition of 31 Days to a More Effective Compliance Program.
Disconnectedness compliance comes from the fact there is not one system which connects the disparate strands of the compliance discipline. Find out more on 31 Days to a More Effective Compliance Program.
The Competitive (Compliance) Advantage of Data
The bottom line is that it is not if but when you begin to incorporate corporate information into your compliance program to make your compliance program more efficient and your business process run more effectively.
The Compliance Function into the 2020s and Beyond
Yesterday we considered the compliance professional in the 2020s and beyond. Today we look at the Compliance Function.
Skills for the Compliance Professional in the 2...
What should compliance practitioners do to move themselves forward professionally in the 2020s and beyond? Find out n this episode of 31 Days to a More Effective Compliance Program.
Future of Compliance Training
What does the future of compliance training look like? Find out on this episode of 31 Days to a More Effective Compliance Program
Communication to see around corners
How can a compliance professional use such an approach to communications, allows a CCO to “see around corners” and why can be one of the greatest strengths of a best practices compliance program?
The ROI of Effective Compliance
We are now at a place where there is sufficient data, academic research and actual use cases demonstrate good ethics and compliance programs are not simply good for business but when properly used, they lead to greater ROI.
Operationalizing Compliance Through a Digital T...
How can you operationalizing compliance through a digital transformation? Find out in today's edition of 31 Days to a More Effective Compliance Program
Taming Complexity in Compliance
Why is taming complexity in compliance critical to compliance program effectiveness? Find out in today's episode of 31 Days to a More Effective Compliance Program.
Originating and Managing a Compliance Ecosystem
Have you ever thought of compliance as an ecosystem? Find out more in today's episode of 31 Days to a More Effective Compliance Program.
Why Business Ventures are Different than 3rd Pa...
Too often compliance professionals do not understand the difference between business ventures and business venture partners and 3rd parties.
Distributor Liability Under the FCPA
In today's episode, we consider three enforcement actions which made clear that there were no distinctions between agents and distributors.
Following the Money Through Distributors
In this episode of 31 Days to a More Effective Compliance Program, I am consider the Polycom FCPA enforcement action to discuss following the money through distributors.
How many franchisors perform compliance due diligence on their prospective overseas franchises?
What is potential franchisor under the FCPA? More than you might think. Find out more in today's 31 Days to a More Effective Compliance Program.
Distributors as business venture partners
Do you consider you distributors as business venture partners? Find out why you should on this episode of 31 Days to a More Effective Compliance Program.
Financial review of your business venture partner
Why is the financial review of your business venture partners so critical? Find out in today's 31 Days to a More Effective Compliance Program.
The Corp Controller and Business Ventures
How can the Corporate Controller be a key to risk management in business ventures? Find out in today's 31 Day's to a More Effective Compliance Program.
Know Your Customer
Why is know your customer becoming more important in the business venture context? Find out on this episode of 31 Days to a More Effective Compliance Program.
Tying it all together for JVs
In this episode, I tie together the risk and risk management strategies for Joint Ventures under the FCPA. In this edition of 31 Days to a More Effective Compliance Program.
Post-acquisition integration plan
What is your post acquisition integration plan? Find out why having one is so critical in this episode of 31 Days to a More Effective Compliance Program.
Pre-acquisition due diligence
A pre-acquisition risk assessment could also be used as a “lens through which to view the feasibility of the business strategy” and help to value the potential target.
Pre-acquisition risk assessment
What is the pre-acquisition risk assessment and how can it lead to safe harbor? Find out in this episode of 31 Days to a More Effective Compliance Program.
Draft Episode for Oct 13, 2020
Why should a company engage in pre-acquisition due diligence in the M&A context? Find out the business reasons in this episode of 31 Days to a More Effective Compliance Program
Safe Harbor for Successor Liability
White collar defense practitioners have long called for a specific safe harbor for companies in the mergers and acquisition context. This clarion call was answered when in July 2018, the DOJ announced a safe harbor.
Auditing Joint Ventures
Joint Ventures present unique compliance risks and must be managed accordingly. Audit rights and their exercise are key risk management tools.
Compliance terms and conditions in JV agreements
What are the compliance terms and conditions you should have in every JV subject to the FCPA? Find out in this episode of 31 Days to a More Effective Compliance Program.
JV Due Diligence
When you bring two entities together to operate jointly, there are several difficult issues to analyze. This is where the due diligence process comes into play. Find out more in this episode of 31 Days to a More Effective Compliance Program.
JV risks under the FCPA
In many ways, JVs present more difficult issues for the compliance practitioner than M&A because of the control issues present in JVs with foreign governments or state-owned enterprises ownership.
The concept of dis-linking was most prominently laid out in Opinion Release 14-02. It provided one of the most concrete statements from the DOJ on the unidimensional nature of compliance in the M&A context.
Key M&A cases under the FCPA
What are some of the key M&A enforcement actions under the FCPA?
Introduction to Business Ventures
This month we consider how to create a more effective compliance program involving business ventures.
Culture as a Foundational Internal Control
To conclude this month's series on Internal Controls, I am joined by Vin DiCianni, Founder and CEO of AMI. We discuss how corporate culture is a foundational internal control. It is a fascinating topic that is not discussed enough by compliance professionals.
In this episode of 31 Days to a More Effective Compliance Program, I am joined by AMI's Eric Feldman to discuss a gap analysis and why it is so critical.
Assessing compliance internal controls under COSO
How can you assess your internal controls? Find out in today's edition of 31 Days to a More Effective Compliance Program
COSO Objective V: Monitoring Activities
The fifth and final Objective is Monitoring Activities and as with all other components of the COSO Cube, Monitoring Activities are part of an inter-related whole and cannot be taken singularly.
COSO Objective IV: Information and Communication
The objective of Information and Communication is not to be taken in a vacuum. Indeed, one of the more interesting aspects of this objective is that it runs not only vertically but also horizontally. Find out more in today's 31 Days to a More Effective Compliance Program
COSO Objective III: Control Activities
Control Activities are the actions established through policies and procedures that help ensure that management’s directives to mitigate risks to the achievement of objectives are carried out. Find out more in today's 31 Days to a More Effective Compliance Program.
COSO Objective II: Risk Assessments
Objective II is designed to provide a company with a dynamic and iterative process for identifying and assessing risks. Find out more in today's 31 Days to a More Effective Compliance Program
COSO Objective I: Control Environment
The first of the five objectives is control environment and it sets the tone for the implementation and operation of all other components of internal control. Find out more in today's 31 Days to a More Effective Compliance Program
What is the COSO 2013 Internal Controls Framework?
What is the COSO 2013 Internal Controls Framework and how does it relate to compliance. We begin a consideration of the COSO Framework in this episode of 31 Days to a More Effective Compliance Program.
Code of Conduct as an internal control
When does a Code of Conduct violation become a FCPA enforcement action? Find out in today's edition of 31 Days to a More Effective Compliance Program.
Board of Directors’ oversight as an internal co...
How does Board of Director oversight act as an internal control? Find out in today's edition of 31 Days to a More Effective Compliance Program.
Internal controls for gifts, travel and enterta...
Today, we consider how to construct internal controls around gifts, travel and entertainment in a best practices compliance program.