Compliance Beat

Your board of directors must stay informed about their compliance duties and stay engaged in your compliance and ethics program to fulfill their obligations as board members. Training your board of directors is a key responsibility for compliance professionals. At times, training your board of directors can be a real challenge. How can you effectively discuss compliance responsibilities and the key role of the board in compliance with board members, both new and old? What is the source law and standards for director's responsibility for compliance? What risks do they face for not being on top of these responsibilities? Compliance is the responsibility of the full board, not just the audit or compliance committee. Eric talks about the expectations outlined in the Sentencing Guidelines and recent United States Department of Justice Fraud Sections' new guidance, the Evaluation of Corporate Compliance Programs. Finally, Eric talks about how important it is to provide real information to the board about the

This time Eric tackles some common (and stubborn) myths about regulatory enforcement and criminal liability. First, we tackle the “Trump Factor”, and the notion that reduced regulation and enforcement is on the way. Eric talks about what we really are seeing with enforcement and the statements coming from regulators and prosecutors, including the USDOJ. Eric… The post What Are Some Corporate Enforcement Myths? appeared first on Compliance Beat.

This time Eric discusses case management and reporting benchmarking. First, why is it a good idea to have a plan in place to gauge the effectiveness of this aspect of your compliance program? Eric explores why it’s a good idea to have a business case put together so that you can budget for tools in… The post Should We Measure Our Case Management and Reporting System? What Are Some Ways to Measure? appeared first on Compliance Beat.

In this episode Eric has a conversation with Ricardo Pellafone, the founder of Broadcat. Eric and Ricardo have a wide-ranging discussion about compliance myths that seem to have a lot of staying power. Including, how having a lot of resources and being very busy does not necessarily equal an “effective” program. As Ricardo paraphrases Hui… The post A Special Conversation with Ricardo Pellafone appeared first on Compliance Beat.

In this episode Eric delves in a little deeper on a common question: who should be involved in a code of conduct project? Of course this depends a lot on what kind of project is being undertaken. Should you revise internally or bring in an outside team? What resources are available to your organization to… The post Who Should Be Involved in a Code of Conduct Revision Project? appeared first on Compliance Beat.

Recently we’ve seen more activity from the Department of Justice (Fraud Section) and other regulators both in the United States and internationally that address compliance and ethics program standards and effectiveness. One topic that’s come up informally in some conversations is whether the Sentencing Guidelines still hold a central role in defining “effectiveness” for a… The post Do The Sentencing Guidelines Matter Anymore? appeared first on Compliance Beat.

Since incentives were first introduced in the Sentencing Guidelines there has been little guidance about what exactly make up incentives for compliance. It’s also probably no surprise that one of the most underdeveloped parts of many compliance and ethics programs is the application of incentives. In this episode Eric talks about some practical things organizations… The post Tips for Compliance and Ethics Program Incentives appeared first on Compliance Beat.

Should you have a web-based code of conduct? A common question that many organizations have when they are updating their code of conduct is should the code be a web-based document? If not, how might an organization use both internal and external-facing web resources? Eric has some ideas about adapting the code, and code content,… The post Using the Web: Should You Have a Web-Based Code of Conduct? appeared first on Compliance Beat.

This time Eric talks about different ways compliance and ethics personnel can help keep the program and an ethical culture front of mind. Eric discusses how you can leverage slower times (often in the summer) to conduct site visits and otherwise engage in outreach. We also provide some practical examples of engagement activities to try… The post Keeping Compliance Front of Mind appeared first on Compliance Beat.

In this episode Eric revisits a topic that is front-of-mind for many these days: involving managers in compliance. Eric discusses how research has shown involving the middle can improve concerns around retaliation and positively impact the culture of the organization. One way to better involve the middle is to make sure managers are armed with… The post Three More Ways to Involve Managers in Compliance and Ethics appeared first on Compliance Beat.

What are some common mistakes that compliance professionals make when communicating about compliance? Since 1991, when the US Sentencing Guidelines first addressed the importance of communication in tandem with formal compliance training, compliance officers have occasionally struggled with how frequently and in what ways to address compliance communication. In this episode, Eric talks about some common issues organizations have faced when considering the more informal side of efforts to educate and inform employees and other stakeholders about compliance risks and issues. Eric also focuses on ways organizations can address these common situations and how the recent the Department of Justice's recent guidance, the Evaluation of Corporate Compliance Programs, and other standards effect communication requirements and expectations. Finally, Eric also offers some specific practical ideas for organizations to consider when addressing compliance communication efforts. The post Compliance Communication Failures appe

What are some strategies and options for the compliance officer that is aware of misconduct occurring at their organization? This can be one of the most complicated topics that a compliance officer can face. And there are not always a lot of good solutions. But what options should the compliance officer consider? And what should the compliance office expect from their organization? This week, Eric explores the answers to these questions. The post Misconduct: Options (& Responsibilities) for Compliance Officers & Three Questions with Garin Bergman appeared first on Compliance Beat.

When we think about third-party management, we often think of due diligence. The Department of Justice Fraud Section's new compliance and ethics guidance, the Evaluation of Corporate Compliance Programs, only mentions due diligence one time. The Evaluation contemplates a holistic, ongoing approach to third-party management in which the process is integrated into other functions, such as procurement. The post What does DOJ’s new guidance say about third-party risk? & Three Questions with Tedrick Housh appeared first on Compliance Beat.

The new Department of Justice's guidance, the Evaluation of Corporate Compliance Programs, discusses the "design and accessibility" of written standards, such as your code of conduct. Does this focus on "design" in particular mean that organizations should reconsider or review the use of interactivity for their code? What does the Department's focus on "communication" and "evaluation" of written standards affect how an organizations evaluates and implements any interactive features? Eric discusses what the new focus on design and accessibility might mean and how organizations can address these expectations in their code of conduct review, revision and development processes. The post DOJ’s New Guidance & Interactive Code of Conduct & Part Two of Our Interview with Alison Taylor appeared first on Compliance Beat.

How does the new Department of Justice's new guidance, the Evaluation of Corporate Compliance Programs, from February 2017 approach the requirements for written standards, including code of conduct? Eric walks through three key takeaways from the Evaluation of Corporate Compliance Programs on how organizations should document and conduct their code of conduct development and review process. We also have Part One of a two part Special Interview with Alison Taylor of BSR. The post The New DOJ Guidance on Code of Conduct & Part One of a Special Interview with Alison Taylor appeared first on Compliance Beat.