FCPA Compliance Report

MARCH 8, 2019 BY TOM FOX In today’s edition of Daily Compliance News: ·      Gulnara Karimova charged with conspiracy to commit money laundering in the whooping amount of $866MM. (FCPA Blog)·      How to win friends and influence enemies? (Financial Times) ·      Facebook says it not prioritizes privacy. Do you believe it? (New York Times)·      What happens when billionaires fight? (Wall Street Journal) Learn more about your ad choices. Visit megaphone.fm/adchoices

In the episode, I consider two different issues around communication skills. The first is communicating across cultural boundaries.  The second is the technique of asking questions to boost leadership. One of the things most critical issues to a compliance function is breaking through a company’s internal cultural boundaries. Learn more about your ad choices. Visit megaphone.fm/adchoices

Innovative use of videos can improve employee engagement and further operationalize your compliance program. Learn more about your ad choices. Visit megaphone.fm/adchoices

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. Learn more about your ad choices. Visit megaphone.fm/adchoices

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.  Learn more about your ad choices. Visit megaphone.fm/adchoices