31 Days to a More Effective Compliance Program
Tom Fox, known as the Compliance Evangelist, hosts this daily podcast series on designing and implementing effective compliance programs. Each month focuses on a different compliance area, such as internal controls, board roles, communication, HR, investigations, third parties, and business ventures. Listeners receive one actionable tip per episode to enhance their compliance program at little or no cost.
Episodes
Day 31 - Leveraging Root Cause Analysis for Effective Compliance
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 30 - The Foreign Extortion Prevention Act
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 29 - Enhancing Compliance through Automation
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 28 - The Importance of Data Governance
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 27 - The Compliance Function in an Organization
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 26 - Elevating the Role and Independence of the Chief Compliance Officer
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 25 - Investigative Findings
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 24 - Internal Reporting and Triage
Welcome to 31 Days to a More Effective Compliance Program, a series by Tom Fox in January 2026, where he will post daily insights on best practices for compliance programs. Each short podcast, lasting 6-8 minutes, will provide three actionable takeaways to help you create, design, or enhance your compliance program at minimal cost. Join daily for valuable guidance on compliance best practices. In
Day 23 - Investigative Protocols
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 22 - Levels of Due Diligence
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 21 - Managing Third Parties
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 20 - Third Party Risk Management Process
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 19 - Evaluating the Risk Management Process
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 18 - Risk Assessments
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 17 - Podcasting for Compliance
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 16 - Effective and Tailored Compliance Training
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 15 - Monitoring and Improving Internal Controls
Welcome to the 31 Days to a More Effective Compliance Program, a series by Tom Fox in January 2026. Each day will feature a brief podcast (6-8 minutes) highlighting a key component of a best-practice compliance program. By the end of the month, participants will be equipped to create or enhance their compliance programs with actionable takeaways at minimal cost. Join daily for insights into compli
Day 14 - Internal Controls
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 13 - Policies and Procedures
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 12- Your Corporate Code of Conduct
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over this 31 days series in January 2026, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key t
Day 11 - Moving Compliance Down into an Organization
Welcome to the 31 Days to a More Effective Compliance Program, a series by Tom Fox in January 2026. Each day will feature a brief podcast (6-8 minutes) highlighting a key component of a best-practice compliance program. By the end of the month, participants will be equipped to create or enhance their compliance programs with actionable takeaways at minimal cost. Join daily for insights into compli
Day 10 - Leadership’s Role in Shaping Corporate Culture and Compliance
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 9 - Continuous Monitoring and Continuous Improvement
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 8 - Building Effective Compliance Through Payroll
Welcome to the 31 Days to a More Effective Compliance Program, a series by Tom Fox in January 2026. Each day will feature a brief podcast (6-8 minutes) highlighting a key component of a best-practice compliance program. By the end of the month, participants will be equipped to create or enhance their compliance programs with actionable takeaways at minimal cost. Join daily for insights into compli
Day 7 - Clawbacks and Holdbacks
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 6 - The M&A Safe Harbor Policy
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 5 - Enhancing Compliance Through Automation
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 4 - Building Effective Data Analytics Programs for Compliance
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 3 - Key Updates in the ECCP: Messaging Apps, Internal Controls, and Compensation
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 2 - The ECCP on Incentives, Consequences, and Clawbacks
Welcome to 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with three key takeaways that you can implement at little or no co
Day 1 - Data-Driven Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over this 31-day series in January 2026, Tom Fox will post a key component of a best-practice compliance program each day. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, with t
Day 31 - Leveraging Root Cause Analysis for Effective Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 30 - The Foreign Extortion Prevention Act
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 29 - Enhancing Compliance through Automation
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 28 - The Importance of Data Governance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 27 - The Compliance Function in an Organization
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 26 - CCO Authority and Independence
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 25 - Responding to Investigative Findings
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 24 - Internal Reporting and Triage
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 23 - Investigative Protocols
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 22 - Levels of Due Diligence
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 21 - Managing 3rd Parties
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 20 - Third-Party Risk Management Process
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 19 - Evaluating Risk Assessments
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 18 - Risk Assessments
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 17 - Podcasting for Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 16 - Effective and Tailored Compliance Training
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be 6-8 minutes short, with three k
Day 15 - Monitoring and Improving Internal Controls
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and will
Day 14 - Internal Controls
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 13 - Policies and Procedures
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 12 - The Importance and Construction of a Corporate Code of Conduct
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 11 - Moving Compliance Down into an Organization
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of the best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, an
Day 10 - Leadership’s Role in Shaping Corporate Culture and Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 9 - Continuous Monitoring and Continuous Improvement
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 8 - Building Effective Compliance Through Payroll
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6–8 minutes, and
Day 7 - Argentieri on Clawbacks and Holdbacks
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 6 - M&A Safe Harbor Policy
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days of the series in January 2025, Tom Fox will post a key part of a best practices compliance program daily. By the end of January, you will have enough information to create, design, or enhance a compliance program. Each podcast will be short, at 6-8 minutes, and
Day 5- Enhancing Compliance Through Automation
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Day 4- Building Effective Data Analytics Programs for Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key
Day 3- Key Updates in the ECCP: Messaging Apps, Internal Controls, and Compensation
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key
Day 2- 2024 ECCP on Incentives, Consequences, and Clawbacks
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short, at 6-8 minutes with three key
Day 1-Data Driven Compliance
Day 1-Data-Driven Compliance
Welcome to a special podcast series on the Compliance Podcast Network, 31 Days to a More Effective Compliance Program. Over these 31 days series in January 2025, I will post a key part a best practices compliance program each day. By the end of January, you will have enough information to create, design or enhancement a compliance program. Each podcast will be short,
31 Days to a More Effective Compliance Program: Day 31 - Using a Root Cause Analysis for Remediation
The 2023 ECCP re-emphasized the need for both performing a root cause analysis but equally importantly using it to remediate your compliance program. It stated, “a hallmark of a compliance program that is working effectively in practice is the extent to which a company is able to conduct a thoughtful root cause analysis of misconduct and timely and appropriately remediate to address the root cause
31 Days to a More Effective Compliance Program: Day 30 - The Foreign Extortion Prevention Act
The compliance community has long recognized the gaping hole in the FCPA. As a supply-side law, it criminalizes the payment of bribes, not the demand to pay a bribe or extortion. The gap was recently filled by the Foreign Extortion Prevention Act (FEPA), which extended crucial protections to Americans working abroad and provided the DOJ with a potent new tool. By criminalizing both the giving and
31 Days to a More Effective Compliance Program: Day 29 -Strategic Considerations for Implementing AI in Compliance
Implementing AI in compliance requires strategic considerations and decision-making. Understanding the impact of AI, maintaining an inventory of tools, considering cost efficiency and risk avoidance, involving all business sectors, and utilizing AI for better data usage are key factors to consider. Balancing exploration and rules, as well as selecting the right AI tools, are challenges that need t
31 Days to a More Effective Compliance Program - Day 28 - Data-Driven Compliance – From Cutting Edge to Table Stakes
Compliance programs play a crucial role in ensuring that companies adhere to legal and ethical standards. In today’s digital age, where data is abundant and easily accessible, the importance of data-driven compliance programs cannot be overstated. This message was driven home very forcefully in a speech in November by Nicole Argentieri, acting assistant attorney general for the Criminal Division.
31 Days to a More Effective Compliance Program - Day 27 - 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. When it came to the corporate compliance function, 2020 FCPA Resource Guide, 2nd edition, under the Hallmarks of an Effective Compliance Program, simply noted the government would “consider whether the company devoted adequate staffing and resources to the
31 Days to a More Effective Compliance Program - Day 26 - CCO Authority and Independence
The role of the CCO has steadily grown in stature and prestige over the years. In the 2020 FCPA Resource Guide, 2nd edition, under the Hallmarks of an Effective Compliance Program, it focused on whether the CCO held senior management status and had a direct reporting line to the Board.
In the 2023 Update to the FCPA Corporate Enforcement Policy, the DOJ lists these factors as follows:
1) The quali
31 Days to a More Effective Compliance Program: Day 25 – Responding to Investigative Findings
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 DOJ or notice letter from the SEC to trigger the attention of the Board of Directors and senior management to the compliance function and the company’s compliance program. Such an event can trigger much gnashing of teeth and expressions of outrage,
31 Days to a More Effective Compliance Program: Day 24 - Internal Reporting and Triaging of Claims
The call, email, or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into an FCPA issue for your company. As the CCO, it will be up to you to begin the process, which will determine, in many instances, how the company will respond going forward. This system has become even more important after the 2022 announcement of the
31 Days to a More Effective Compliance Program: Day 23 – The Investigation Protocol
Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal company hotline, anonymous tips, or a report directly from the business unit involved. You can make the decision on whether or not to investigate with consultation with other group
31 Days to a More Effective Compliance Program - Day 22 - 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 to develop a mechanism to determine the appropriate level of due diligence and then implement that going forward.
The 2023 ECCP stated, “A well-designed compliance program should apply risk-based due diligence to its third-party rela
31 Days to a More Effective Compliance Program: Day 21 - Managing Your Third Parties
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a business justification, questionnaire, due diligence, evaluation and compliance terms and conditions in contracts. However, as many companies mature in their compliance program
31 Days to a More Effective Compliance Program: Day 20 – The Third Party Risk Management Process
The DOJ expects an integrated approach that is operationalized throughout the company. This means you must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party risk management that will fulfill the DOJ requirements as laid out in the 2023 FCPA Resource Guide, 2nd edition, and in the Hallmarks of an Effective Compliance Program
31 Days to a More Effective Compliance Program: Day 19 - Evaluating a Risk Assessment
One way to evaluate risks as determined by the company’s risk assessment is through a risk matrix. Once risks are identified, they are then rated according to their significance and likelihood of occurring and then plotted on a heat map to determine their priority. The most significant risks with the greatest likelihood of occurring are deemed the priority risks, which become the focus of your rem
31 Days to a More Effective Compliance Program - Day 18 - Risk Assessments
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your organization’s business from a commercial perspective, on how your organization has identified, assessed, and defined its risk profile, and, finally, on the degree to which the program de
31 Days to a More Effective Compliance Program - Day 17 - Podcasts for Compliance Training and Corporate Culture
One of the biggest benefits of podcasting is that it allows a compliance function to connect with their audience on a more personal level. Unlike traditional forms of advertising, which often come across as impersonal and sales-driven, podcasts enable businesses to build a loyal following by offering valuable and engaging content. This can include interviews with industry experts, behind-the-scene
31 Days to a More Effective Compliance Program: Day 16 - Tailored and Effective Compliance Training
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA, your specific company compliance program, and to create and foster a culture of compliance. While it seems axiomatic that compliance training is the mainstay of any best practices compliance program, the conversation around training has evolved over the years.
The importance of determin
31 Days to a More Effective Compliance Program: Day 15 - Monitoring and Improvement of Internal Controls
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law, such as Sarbanes-Oxley (SOX)? Cristina Revelo said she would start out with some basic questions, such as “How often would something be manually approved? How often are controls skipped? What are the levels of approvals that you have a
31 Days to a More Effective Compliance Program: Day 14 - Internal Controls
What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as:
An internal control is an action or process of interlocking activities designed to support the policies and procedures detailing the specific preventative, detective, corrective, directive, and corroborative actions required to achieve the desired process out
